United States

This section catalogues ISDA’s work in the United States in the Association’s core areas of focus: documentation, public policy, market structure, market practices, research and other areas

DateTitle / DescriptionDocuments
July 18, 2016
ISDA Comment Letter – CFTC 2016 IRS Clearing Mandate
ISDA response to 2016 expansion of CFTC IRS Clearing Mandate.
ISDA Comment Letter - CFTC 2016 IRS Clearing Mandate.pdf
June 28, 2016
Industry Groups Urge Focus on Risk Controls in CFTC’s Proposed Rule on Automated Trading
The FIA, FIA Principal Traders Group (FIA PTG), International Swaps and Derivatives Association, Inc. (ISDA), Managed Funds Association (MFA), and SIFMA’s Asset Management Group (SIFMA AMG) sent a joint letter to the Commodity Futures Trading Commission (CFTC) in response to the reopened comment period on their proposed rule on regulation automated trading (Reg AT).
REG AT Roundtable Group Comment Letter  062416.pdf
March 28, 2016
ISDA Response to SEC Proposal on Use of Derivatives by Registered Investment Companies and Business Development Companies
ISDA appreciates the opportunity to submit these comments with respect to the notice of proposed rulemaking published by the Securities and Exchange Commission (SEC) regarding proposed Rule 18f-4 under the Investment Company Act of 1940 and the use of derivatives by registered investment companies and business development companies.
ISDA Comment -- SEC Asset Manager Proposal 032816 (002).pdf
March 16, 2016
ISDA Comments on Regulation Automated Trading; Proposed Rule: 17 CFR Parts 1, 38, 40
ISDA comment letter to the Commodity Futures Trading Commission (CFTC) on Proposed Rule, Regulation Automated Trading.
Regulation AT-comment-03-16-16 (002).pdf
February 24, 2016
Principles for US/EU Trading Platform Recognition
This paper analyzes the regulatory frameworks in the US and EU, with the aim of determining whether EU trading platforms should be deemed comparable with those in the US. Underpinning the analysis is the principle that regulators should focus on broad outcomes and similarities, rather than conduct a granular, rule-by-rule comparison of the two frameworks.
Principles for US-EU Trading Platform Recognition.pdf
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