Responses

Comment Letters, responses to Consultation Papers, responses to Requests for Comment.


DateTitle / DescriptionDocuments
September 15, 2017
Response to Sections 2.37-2.63 of the CPMI-IOSCO Consultative Report on the Harmonisation of critical OTC derivatives data elements (other than UTI and UPI) – third batch
ISDA's response to Sections 2.37-2.63 of the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) third consultation on the Harmonisation of critical OTC derivatives data elements (CDE), other than UTI and UPI.
CPMI IOSCO_CDE3_ISDA Response_2.37-2.63- Hardcopy View_15 September 2017_FINAL.pdf
August 30, 2017
Response to CPMI-IOSCO's Consultative Report on the Harmonisation of critical OTC derivatives data elements (other than UTI and UPI) – third batch (Sections 2.1-2.36; 2.64-2.77)
ISDA's response to Sections 2.1-2.36; 2.64-2.77 of the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) third consultation on the Harmonisation of critical OTC derivatives data elements (CDE), other than UTI and UPI.
CPMI IOSCO_CDE3_ISDA Response_2.1-2.36_2.64-2.77- Hardcopy View_30 August 2017_FINAL.pdf
August 21, 2017
Response to the CFTC DMO Request for Comments on the Roadmap to Achieve High Quality Swaps Data (Parts 43, 45, and 49)
ISDA and SIFMA joint response to the U.S. Commodity Futures Trading Commission (CFTC) Division of Market Oversight Request for Comments on the Roadmap to Achieve High Quality Swaps Data related to the review of swap reporting rules in Parts 43, 45 and 49.
ISDA-SIFMA_comments_CFTC_DMO_Roadmap_Swap_Data_Reporting_21 Aug 2017_FINAL.pdf
May 5, 2017
Response to FSB’s consultation on the Proposed Governance Arrangements for the Unique Transaction Identifier (UTI)
The International Swaps and Derivatives Association (ISDA) and the Global FX Division (GFXD) of the Global Financial Markets Association (GFMA) joint response to the Financial Stability Board’s consultation on the Proposed Governance Arrangements for the Unique Transaction Identifier (UTI).
FSB_UTI_Governance_Response_5 May 2017_PUBLIC.pdf
November 30, 2016
Response to CPMI-IOSCO's Consultative Report on the Harmonisation of critical OTC derivatives data elements (other than UTI and UPI) – second batch
ISDA's response to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) second consultation on the Harmonisation of critical OTC derivatives data elements (CDE), other than UTI and UPI.
CPMI-IOSCO_CDE2_ISDA_Response_30_November_2016_PUBLIC.pdf
September 30, 2016
Response to CPMI-IOSCO's second Consultative Report on the Harmonisation of the Unique Product Identifier (UPI)
ISDA's response to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) second consultative report on the Harmonisation of the Unique Product Identifier (UPI).
CPMI-IOSCO_UPI2_ISDA_Response_30_September_2016_Final.pdf
August 30, 2016
Joint letter to the LEI ROC policy document regarding international branch LEIs
ISDA and the GFMA joint letter to the LEI ROC and the GLEIF regarding the LEI ROC policy document “Including data on international/foreign branches in the Global LEI System” (11 July 2016).


The letter emphasizes the importance of the consistent global application of branch LEI standards by regulators and market participants across jurisdictions with respect to derivatives trade reporting.

ISDA_GFMA_International_Branch_LEI__30Aug2016_FINAL.pdf
April 6, 2016
Response to Proposed Multilateral Instrument 96-101
ISDA’s response to the request for comments on Proposed Amendments to Multilateral Instrument 96-101 Trade Repositories and Derivatives Data Reporting issued by regulators in 10 provinces and territories of Canada.
ISDA_AmendedMLILetter_6Apr2016_FINAL.pdf
March 23, 2016
Response to ESMA’s Consultation Paper on Guidelines on transaction reporting, reference data, order record keeping & clock synchronization (ESMA/2015/1909)
ISDA’s response to ESMA’s Consultation Paper on proposed Guidelines for certain data and reporting aspects of MiFIDII / MiFIR found in Regulatory Technical Standards 22, 23, 24 and 25 of the regulation.
Response_ESMA Guidelines on trans rep, ref data, ord rec keeping & clock synch_23 March 2016.pdf
March 7, 2016
Response to CFTC’s Draft Technical Specifications
ISDA response to the CFTC’s request for comments on its Draft Technical Specifications for Certain Swap Data Elements.
CFTC_Data Elements_ISDA_FINAL_7 Mar 2016.pdf