United States


DateTitle / DescriptionDocuments
September 14, 2012
Comment Letter on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
Letter to the Commodity Futures Trading Commission (CFTC) regarding Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
ISDA-SIFMA-CFTCMarginCommentLetter091412.pdf
September 12, 2012
Regulation of OTC derivatives markets: A comparison of EU and US initiatives
Prepared by Clifford Chance in September 2012. This paper is not intended to be comprehensive or to provide legal advice.
CliffCh-ISDA reg comparison of EU-US initiatives Sept 2012.pdf
September 6, 2012
Comment Letter on the Clearing Requirement Determination under Section 2(h) of the CEA
Letter to the Commodity Futures Trading Commission (CFTC) regarding NPR Clearing Requirement Determination under Section 2(h) of the CEA
CFTC Proposed Clearing Determination - ISDA Comment Letter %28703017939_10%29.pdf
August 27, 2012
Comment Letter on the Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act
Letter to the Commodity Futures Trading Commission (CFTC) regarding Cross-Border Guidance and Related Privacy Implications
Comment Letter - CFTC Reporting Obligations FINAL 082712.pdf
August 10, 2012
Proposed Interpretive Guidance and Policy Statement: Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (RIN 3038-AD57); Notice of Proposed Exemptive Order and Request for Comment (RIN 3038-AD85)
Letter to CFTC on Extraterritoriality (ET)
CFTC ISDA Comment - Cross-Border and Int Order FINAL 081012.pdf
July 3, 2012
CFTC Reporting Rules - Compliance Challenges
ISDA letter to CFTC on reporting obligations under Part 20, Part 43, Part 45 and Part 46 of the Code of Federal Regulations (CFR)
ISDA Reporting Challenges- 070312.pdf
June 29, 2012
ISDA-SIFMA Response to CFTC Proposed Rulemaking - Aggregation, Position Limits for Futures and Swaps
Comment Letter
ISDA SIFMA Aggregation Comment Letter.pdf
May 29, 2012
Aggregation, Position Limits for Futures and Swaps
Letter to the Commodity Futures Trading Commission (CFTC) from ISDA and SIFMA regarding Aggregation, Position Limits for Futures and Swaps
ISDA SIFMA Aggregation Comment Letter 2817 C F R  Part 151 Fed  Reg  3176829.pdf
May 29, 2012
Proposed Rulemaking Schedule of CFTC Title VII Rulemaking
Letter to the Commodity Futures Trading Commission (CFTC) from SIFMA and ISDA regarding Commissioner O’Malia’s Proposed Rulemaking Schedule
SIFMA ISDA Comment on Proposed CFTC Rulemaking Schedule %283%29.pdf
May 17, 2012
Treatment of Inter-affiliate Transactions
Letter to the Commodity Futures Trading Commission (CFTC) from ISDA and SIFMA regarding Treatment of Inter-affiliate Transactions
CFTC - Inter-affiliate clearing FINAL 51412.pdf