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
May 26, 2011
Reopening and Extension of Comment Periods for Rulemakings Implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act
Joint Associations Comment Letter
JointTradeAssociation_Reopening_and Extension_of_Comment_Letter(76-FR-25274).pdf
May 25, 2011
ISDA Chairman Stephen O'Connor's Testimony Before the US House of Representatives Committee on Agriculture, Subcommittee on General Farm Commodities and Risk Management
Transcript of testimony
TestimonytoHouseAgSubCommittee20110525.pdf
May 17, 2011
ISDA’s Comments on Proposed Interpretive Order: Anti-Disruptive Practices Authority
Comment letter to CFTC
Anti-Disruptive_Practices_Comment-051711.pdf
May 4, 2011
Phase-In Schedule for Requirements for Title VII of the Dodd-Frank Act
Comment Letter from ISDA with FIA, Financial Services Forum and SIFMA, addressed to CFTC and SEC.
Title VII Implementation Letter.pdf
April 29, 2011
ISDA’s Comments on Clearing Agency Standards for Operation and Governance
SEC’s NPR: Clearing Agency Standards for Operation and Governance
SEC-NPR-042911.pdf
April 29, 2011
Joint Comment Letter to SEC on SEC's NPR
Joint Comment Letter (ISDA with four other associations) on reopening of the comment period on ownership limitations and governance requirements for security-based swap clearing agencies, security-based swap execution facilities, and national securities exchanges with respect to security-based swaps under Regulation MC
Comment-Letter-to-the-SEC-on-Proposed-Ownership-Limitations-(File-NoS7-27-10).pdf
April 8, 2011
ISDA’s Comments on Processing, Clearing, and Transfer of Customer Positions
CFTC’s NPR: Processing, Clearing, and Transfer of Customer Positions
CFTC_Comment_NPR-Processing.pdf
April 8, 2011
ISDA & SIFMA Comments to CFTC on Documentation
Comment letter on the proposed rulemakings re: (1) Swap Trading Relationship Documentation Requirements for Swap Dealers and Major Swap Participants and (2) Orderly Liquidation Termination Provision in Swap Trading Relationship Documentation for Swap Dealers and Major Swap Participants
ISDA-SIFMA CFTC Comment - Documentation -040811.pdf
April 4, 2011
ISDA’s & SIFMA’s Comments on Registration and Regulation of Security-Based SEFs
SEC’s NPR: Registration and Regulation of Security-Based Swap Execution Facilities
ISDA-SIFMA_Final_SB-SEF_Letter.pdf
April 1, 2011
Commodity Options and Agricultural Swaps
Letter to CFTC on NPR.
0411 Commodity Ag Swaps FINAL 040111.pdf