United States


DateTitle / DescriptionDocuments
October 12, 2012
Comment Letter on Further Definition of "Swap", "Security-Based Swap", and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
Letter to the Commodity Futures Trading Commission (CFTC) regarding Further Definition of "Swap", "Security-Based Swap", and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
CFTC letter - defintions - vol optionality and usage 101212.pdf
October 1, 2012
Dodd-Frank Act v. EMIR - Confirmation, reconciliation, compression and documentation rules: October 2012
This paper summarises and compares: CFTC rules: the final rules adopted by the U.S. Commodity Futures Trading Commission (CFTC) in August 2012 under section 4s(i) of the Commodity Exchange Act (CEA) (added by section 731 of the Dodd-Frank Act) prescribing standards for swap dealers (SDs) and major swap participants (MSPs) related to the timely and accurate confirmation, reconciliation, compression and documentation of swaps (17 CFR §23.500 through §23.505); and Draft EU rules: the corresponding provisions of the draft regulatory technical standards (RTS) specifying the requirements of Article 11(1) of the EU Regulation on OTC derivatives, central counterparties and trade repositories (EMIR) requiring financial counterparties (FCs) and non-financial counterparties (NFCs) to have appropriate procedures and arrangements to measure, monitor and mitigate operation risk and counterparty credit risk. The draft RTS were adopted by the European Securities and Markets Authority (ESMA) and submitted to the European Commission for endorsement in September 2012 This paper is not intended to be comprehensive or to provide legal advice.
Dodd-Frank Act v. EMIR.pdf
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