ISDA Focus: Dodd-Frank

The rule-making process and ISDA's views

ISDA supports regulatory efforts to increase the safety and soundness of financial and OTC derivatives markets. The Association has actively participated in the Dodd-Frank rule-making process by providing statistics, studies and comment letters to members of Congress, the SEC and the CFTC.

Click here to learn about the Dodd-Frank Documentation Initiative and ISDA Amend.

Click here to visit the page for ISDA August 2012 Dodd-Frank Protocol Management.

Recent comment letters from ISDA are below.


DateTitle / DescriptionDocuments
August 8, 2011
ISDA’s Comments regarding Protection of Collateral for Cleared Swaps
Comment Letter to CFTC
ISDA_-_Cleared_Comment_Letter.pdf
July 22, 2011
ISDA Comment Letter regarding Product Definitions
Sent to CFTC & SEC
Product_Defs_Letter_-Final.pdf
July 11, 2011
ISDA and SIFMA’s Comments regarding Margin and Capital Requirements for Covered Swap Entities
ISDA and SIFMA’s Comments regarding Margin and Capital Requirements for Covered Swap Entities. Sent to the OCC, FDIC, Farm Credit Administration, FHFA & Board of Governors of the Federal Reserve System
ISDA and SIFMA Comment Letter-Margin and Capital Requirements for Covered Swap Entities.pdf
July 6, 2011
Margin and Capital Requirements for Covered Swap Entities
Letter from ISDA/SIFMA to OCC, Federal Reserve, FDIC, Federal Housing Finance Agency, Farm Credit Administration
0706 ISDA and SIFMA Comment Letter-Margin and Capital Requirements for Covered Swap Entities.pdf
June 16, 2011
ISDA Chairman Stephen O’Connor's testimony before the House Financial Services Committee
Testimony text from a hearing on “Financial Regulatory Reform: The International Context”.
Stephen O'Connor Testimony - House Committee Fin Serv 061611.pdf
June 10, 2011
Effective Date Under Sections 754 and 739 of Dodd-Frank
Comment letter to CFTC from Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association, Investment Company Institute, Securities Industry and Financial Markets Association, U.S. Chamber of Commerce
0610 Dodd-Frank Effective Date Request.pdf
June 10, 2011
Request for Clarification and Relief Under Section 774 of Dodd-Frank
Letter to Securities and Exchange Commission from American Bankers Association, Financial Services Roundtable, Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association, Investment Company Institute, Securities Industry and Financial Markets Association, U.S. Chamber of Commerce
0610 Dodd Frank SEC July 16 Letter.pdf
June 9, 2011
ISDA’s Comments regarding Swap Data Recordkeeping and Reporting Requirements: Pre-Enactment and Transition Swaps
Comment letter to CFTC
SwapData_Recordkeeping_and_ReportingRequirements_Pre-Enactment_and_TransitionSwaps.pdf
June 2, 2011
ISDA’s Comments on regarding the order in which the Dodd-Frank related rulemakings should be finalized
Comment letter to CFTC
CFTC-rulefinalization-060211-FINAL.pdf
May 31, 2011
Re-proposal of Rules Implementing Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Joint Associations Comment Letter
JointTradeAssociationTitleVII_Reproposal_letter_5-31-11.pdf