United States


DateTitle / DescriptionDocuments
January 21, 2016
ISDA/SIFMA Comments on CFTC Swap Dealer De Minimis Exception Preliminary Report
Description: ISDA/SIFMA Comment Letter to CFTC on the Swap Dealer De Minimis Exception Preliminary Report published by the CFTC regarding the definition of the term “swaps dealer” and the calculation of the de minimis threshold as required by Regulation 1.3(ggg)(4)(ii)(B).
ISDA SIFMA Comments on Swap Dealer De Minimis Exception Preliminary Repo   .pdf
July 21, 2015
ISDA Audio Webinar: Dodd-Frank Five years On
ISDA Chief Executive Officer Scott O’Malia summarizes the progress made in implementing Dodd-Frank derivatives reforms, and highlights the areas where further work is needed.

Dodd-Frank Five Years On Audio Webinar
Dodd-Frank 5th Year Anniversary Webcast Slides FINAL.pdf
July 20, 2015
Dodd-Frank Five Years On: Significant Progress and Outstanding Challenges
Five years on from the Dodd-Frank Act being signed into law, significant progress has been made in implementing derivatives market reforms, but a number of outstanding issues need to be resolved.
Dodd-Frank FINAL.pdf
July 13, 2015
ISDA Response to SEC Cross-Border Proposal
ISDA Comment Letter to the Securities and Exchange Commission's Application of Certain Title VII Requirements to Security-Based Swap Transactions Connected With a Non-U.S. Person's Dealing Activity That Are Arranged, Negotiated, or Executed by Personnel Located in a U.S. Branch or Office or in a U.S. Branch or Office of an Agent; Proposed Rules (RIN 3235-AL73).
ISDA-Comment-lttr (SEC Cross-Border Proposal 7-13-15).pdf
June 15, 2015
Petition for Rulemaking to Amend Parts 1 (General Regulations under the Commodity Exchange Act), 37 (Swap Execution Facilities) and 43 (Real-Time Public Reporting) of the Commodity Futures Trading Commission Regulations
ISDA respectfully petitions the Commodity Futures Trading Commission (CFTC) under Commission regulation 13.2 to amend certain provisions in Parts 1, 37 and 43 of the Commission’s regulations. ISDA requests that the Commission amend certain provisions of the Commission’s regulations to more closely adhere to Congressional intent to establish a swaps trading platform regime that allows for flexible execution of swaps, to reduce undesirable regulatory outcomes that threaten the efficient functioning of markets, and to achieve cross-border harmonization of execution rules.
ISDA CFTC Petition.pdf
April 1, 2015
Path Forward for Centralized Execution of Swaps: Key Principles
The execution of standardized derivatives on an exchange or electronic trading platform was a key objective from the G-20 summit in 2009, and regulations have either been implemented or are being developed in several key jurisdictions. However, ISDA and its members are concerned about the potential for divergences in how these rules are applied in each jurisdiction, which could lead to market fragmentation, low trading liquidity, duplicative compliance requirements and increased risk. This paper sets out common principles to help ensure regulatory consistency of centralized trading rules, and so facilitate equivalence and substituted compliance determinations.
Path Forward for Centralized Execution of Swaps FINAL.pdf
February 24, 2015
Public comment on the IOSCO Task Force on Cross-Border Regulation Consultation Report
ISDA appreciates the International Organization of Securities Commissions (IOSCO) Task Force on Cross-Border Regulation’s engagement with the industry throughout this consultation process. ISDA has previously submitted comments to the Task Force on a number of specific issues, and highlighted how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. We appreciate the efforts of the Task Force, in this latest Consultation Report, to identify tools at a regulator’s disposal to address cross border regulation. In this letter, ISDA reiterates how cross-border regulatory harmonization could be achieved, and suggests ways in which IOSCO can reduce undesirable regulatory outcomes that threaten the efficient functioning of markets.
IOSCO Cross Border consultation response for submission.pdf
May 29, 2014
IOSCO Task Force on Cross-Border Regulation invitation for industry submissions
ISDA appreciates the IOSCO Task Force on Cross-Border Regulation’s engagement with the industry at meetings in Hong Kong on April 7, London on April 25 and Washington, DC on April 28, 2014. Further to discussions during those meetings, ISDA wishes to comment on a number of specific issues, and highlight how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. This also affects other product areas and, more importantly, threatens the efficiency with which ‘real economy’ end-users can manage and transfer business risk to financial markets.
IOSCO Letter Cross Border 5 29.pdf
March 7, 2014
Request for Comment on Application of Commission Regulations to Swaps Between Non-U.S. Swap Dealers and Non-U.S. Counterparties Involving Personnel or Agents of the Non-U.S. Swap Dealers Located in the United States
ISDA Letter to CFTC.
59777RobertPickel.pdf
February 10, 2014
Notice of Proposed Rulemaking – Position Limits for Derivatives (RIN 3038-AD99)
ISDA/SIFMA Comment Letter to CFTC.
FINAL ISDA-SIFMA Position Limits NPRM Comment Letter (Feb  10 with Annexes).pdf