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
January 23, 2013
Comment Letter on Margin Requirements
Comment Letter to the SEC regarding Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers
ISDA Margin Response to the SEC.pdf
January 17, 2013
Real-Time Reporting FAQ
The start of real-time reporting of interest rate and credit default swaps has raised some questions regarding the information that needs to be real-time reported with respect to swaps allocated after execution. This document provides guidance around some of the issues raised.
Real Time reporting FAQ v4-clean.pdf
December 27, 2012
By When? – The CFTC’s Dodd-Frank Compliance Dates
Mayer-Brown has prepared this matrix to catalog the “by when” dates presently found in many of the final and proposed regulations published by the Commodity Futures Trading Commission, as modified by recent moderating actions of the CFTC and its staff.
DF Effectiveness Timelines.pdf
December 19, 2012
Implementing Dodd-Frank: The CFTC’s Moderating Actions - ISDA’s Requests (updated December 19, 2012)
Presentation by Joshua Cohn and Curtis Doty, Mayer Brown LLP. This is an update of the presentation originally dated December 16, 2012.
CFTC No Action - Mayer Brown ISDA slides 121912.pdf
November 26, 2012
Re-Opening of Comment Period re: Margin and Capital Requirements for Covered Swap Entities – Comments on Margin Requirements
Letter to OCC, Federal Reserve, Federal Housing Finance Agency, Farm Credit Administration and Federal Deposit Insurance Corporation
Margin for Uncleared Letter.pdf
November 26, 2012
Comment Letter on Margin for Uncleared
Comment Letter to the US Prudential Regulators regarding Margin for Uncleared
Margin for Uncleared Letter.pdf
November 17, 2012
Request for Division of Market Oversight Staff No-Action Letter Pursuant to CFTC Regulation 140.99, Reporting Requirements for Bespoke or Complex Products
ISDA letter to Mr. Richard Shilts, Director, Division of Market Oversight, Commodity Futures Trading Commission (CFTC)
NAL - Reporting of Bespoke or Complex Swaps.pdf
October 25, 2012
Comment Letter to CFTC on Reporting of Post-Priced Swaps
Letter to Richard Shilts, Director, Division of Market Oversight, Commodity Futures Trading Commission
CFTC Letter PRS final - 102512.pdf
October 25, 2012
Comment Letter on the Reporting of “Post-Priced” Swaps
Letter to the Commodity Futures Trading Commission (CFTC) regarding the Reporting of “Post-Priced” Swaps
CFTC Letter PRS final - 102512 (3).pdf
October 19, 2012
Notice of Proposed Rulemaking - Regulatory Capital Rules: Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements
Letter to Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation. This response is targeted to the specific risk-based capital requirements for derivative and repo-style transactions that are cleared on central counterparties (CCP Rules). (OCC RIN 1557-AD46; OCC Docket ID OCC-2012-0009; FRB RIN 7100 AD 87; FRB Docket No. R-1442; FDIC RIN 3064-AD96)
Letter to Joint Agencies 19 October 2012 re CCP exposures.pdf