The Regulatory Committee evaluates and responds to proposals from international banking and securities regulators as well as individual country legislators. ISDA's primary objective is to help public policymakers arrive at a responsible and appropriate supervisory framework for a rapidly evolving financial marketplace in which derivatives are a fundamental component.

  • Europe Chair: Bill Eldridge (Credit Suisse)
  • Japan Co-Chair: (See Japan Committee)
  • North America Co-Chair: Gregory Zerzan (ISDA)

How to Join

US REGULATORY ISSUES
SUBJECT STATUS AVAILABLE DOCUMENTS
Joint Association Comment Letter on SEC Rule 144/145 Proposals
Submitted September 21, 2007
Joint Association Rule 144 Comment Letter
Prohibition of Energy Market Manipulation Submitted November 17, 2005 ISDA files Submission with FERC on Market Manipulation
Release No. IA-2266 (File No. S7-30-04) Submitted August 13, 2004 Request for extension of deadline for comment on SEC Hedge Fund Proposal
Interagency Proposed Guidelines on Complex Structured Finance Activities Submitted June 10, 2004 Joint Trade Association Extension Request Letter
ISDA urges the Senate Finance Committee and House Ways and Means Committee to preserve current law "qualified covered call" (QCC) treatment for OTC options.
Submitted May 19, 2004
ISDA heads coalition opposing Feinstein/Lugar/Levin energy market amendment Submitted November 04, 2003 ISDA Letter to The Honorable Bill Frist and the Honorable Tom Daschle
ISDA's Statement Before the United States House of Representatives Subcommittee on General Farm Commodities and Risk Management Committee on Agriculture Submitted June 19, 2003 Prepared statement
ISDA led coalition of trade associations in efforts to have the Senate table indefinitely Senator Feinstein Bill S 509 on June 11.   N/A
ISDA Opposition to Feinstein Energy Derivatives Amendment Submitted April 8, 2002 Industry Letter, Legal Analysis
Amicus Brief - Commodity Futures Modernization Act (Cary Oil Co. v. MG Refining and Marketing) Submitted February 22, 2002 Memo on United States District Court Southern District of New York
ISDA, Financial Industry Trade Associations, and Financial Regulators Urge Passage of Netting Provisions this Year Submitted November 14, 2001 Press Release, Industry Letters, Regulator Letter
Impact of OFHEO's Risk-Based Capital Rule on OTC Derivatives Submitted October 10, 2001 ISDA Comments on OFHEO's Risk-Based Capital Rule

EUROPEAN REGULATORY ISSUES
SUBJECT STATUS AVAILABLE DOCUMENTS
CDWG (ISDFA-FOA-EFET) response to CESR (Committee of European Securities Regulators)- ERGEG (European Regulators' Group for Electricity and Gas) Call for Evidence on Record-Keeping and Transparency in Electricity and Gas Wholesale Markets Submitted 26 March 2008 CDWG (ISDFA-FOA-EFET) response to CESR-ERGEG Call for Evidence on Record-Keeping and Transparency in Electricity and Gas Wholesale Markets
CDWG (ISDFA-FOA-EFET) response to UK Discussion Paper on Commodities (with view to UK approach at EU level in discussions in CESR and CEBS) Submitted 14 March 2008 CDWG (ISDFA-FOA-EFET) response to UK Discussion Paper on Commodities (Annex 2 and Annex 3)
CDWG (ISDA-FOA-EFET) response to CESR-CEBS call for Evidence on Commodities Submitted 3 March 2008 CDWG (ISDA-FOA-EFET) response to CESR-CEBS call for Evidence on Commodities
Submission on European Commission draft Code of Conduct for Interest Representatives. Sent 15 February 2008. ISDA submission to consultation on European Commission Code of Conduct for Interest Representatives
ISDA letter on global regulatory convergence issues in advance of IOSCO Technical Committee meeting in Tokyo, 8 and 9 November 2007. Sent October 19, 2007 ISDA letter on global regulatory convergence issues
ISDA, in cooperation with 5 other trade associations, has urged EU Energy Commissioner Piebalgs to reconsider upcoming proposals for transparency requirements and transaction reporting in wholesale (physical and derivative) markets in electricity and gas. ISDA and the other associations involved (the FOA, BBA, EFET, LIBA and SIFMA) believe that the proposals (scheduled for adoption on 19 September) might damage these markets by imposing a disproportionate regulatory burden on participants in these markets, and has called for a more thorough review of the issue (which the associations believe has not been subject to sufficiently wide or through consultation or impact assessment). The associations also point out that the proposals (originating in the Energy Directorate-General of the European Commission) would contradict the findings of a recent review by the Internal Market Directorate-General on transparency requirements in markets other than equities (including commodity derivatives). Submitted August 14, 2007 ISDA-FOA-BBA-EFET-LIBA-SIFMA letter and annex detailing concerns regarding upcoming proposals for transparency and transaction reporting requirements in electricity and gas wholesale (physical and derivative) markets.
Industry Warns Against Inappropriate Regulation of Commodity Derivatives Submitted June 20, 2007 Call for Evidence - Review of Commodity and Exotic Derivatives and Related Business as Required by MIFID and Recast CAD
ISDA-FOA-EFET Response to Call for Evidence on Commodity and Exotic Derivatives Submitted May 22, 2007 Joint ISDA-FOA-EFET Response to Call for Evidence on Commodity and Exotic Derivatives
Response to FSA Consultation Paper 06/14: Implementing MIFID for Firms and Markets Submitted October 31, 2006 ISDA Joins with Other Trades In Response to FSA CP06/14 -Implementing MIFID for Firms and Markets
ICMA, ISDA and TBMA Jointly Respond to FSA Discussion Paper Implementing MiFID’s Best Execution Requirements Submitted July 14, 2006 MiFID: FSA Discussion Paper on Best Execution (DP 06/3): Response From BMA/ICMA/ISDA: Summary
Joint Associations response to CESR Call for evidence on Consolidation of Market Transparency Data Submitted April 24, 2006 Joint Associations response to CESR Call for evidence on transparency consolidation
ISDA Letter regarding CESR's Advice on Clarification of Definitions concerning Eligible Assets for Investments of UCITS - 2nd Consultation Paper
Submitted December 05, 2005 ISDA Letter re CESR consultation on eligible assets for investment of UCITS
ISDA Letter regarding FSA Discussion Paper on Trading transparency in the UK secondary bond markets Submitted December 05, 2005 ISDA Letter regarding FSA Discussion Paper on Trading transparency in the UK secondary bond markets
Joint Association response to CESR Paper on Mediation Mechanism Submitted December 05, 2005 Joint Association response to CESR Paper on Mediation Mechanism
ISDA comment letter to FSA regarding FSA Quarterly consultation (No.5) Submitted September 14, 2005 ISDA comment letter regarding FSA Quarterly consultation (No.5)
ISDA Comment Letter to Department for Work and Pensions on the draft Occupational Pension Schemes (Investment) Regulations 2005
Submitted June 20, 2005 ISDA Letter to Department for Work and Pensions on Investment Requirements for Pensions
ISDA Comment Letter to CESR regarding CESR's Advice on Clarification of Definitions concerning Eligible Assets for Investments of UCITS
Submitted June 09, 2005 ISDA Letter to CESR on Clarification of Definitions concerning Eligible Assets for Investments of UCITS
Joint Associations’ response to CESR's March 2005 consultation on draft technical advice on possible implementing measures of the Directive 2004/39/EC on Markets in Financial Instruments (MIFID): Investment advice, best execution, market transparency, Second consultation paper
Submitted April 04, 2005
Joint Associations’ response to CESR consultation on best execution and market transparency
Joint Associations response to CESR on its draft technical advice on possible implementing measures of the Directive 2004/39/EC on Markets in Financial Instruments ("MFID") regarding admission to trading
Submitted March 03, 2005 Joint Associations response to CESR consultation on admission to trading
Joint Associations response to CESR on its draft technical advice on possible implementing measures of the Directive 2004/39/EC on Markets in Financial Instruments ("MFID") regarding professional client agreements (ref: CESR/04-689, December 2004)
Submitted February 18, 2005 Joint Associations response to CESR consultation on professional client agreements
ISDA paper on Regulations vs Directives
ISDA paper discussing Regulations vs Directives implementing measures in regard to the Directives on Markets in Financial Instruments (MiFID)
Regulations vs Directives, October 2004
Joint Association response to CESR consultation on MiFID, Parts 1 and 2 Part 1 Submitted September 17, 2004;
Part 2 Submitted October 4, 2004
Part 1 response; Part 2 response
European Commission's Communication on a European contract Law Consultation Text of the Communication

ISDA's submission
Review of the Investment Services Directive Second reading in the Parliament and Council Council common Position

Coreper Compromise Package to the Parliament second reading

Joint Associations position

EMAC second reading accepted amendments proposed by ISDA on commodity derivatives


Text of the proposal

Joint Associations position
ISD: level II implementing measures -Commission mandates to CESR and -CESR consultation Commission provisional mandate to CESR

CESR concept paper on transaction reporting and cooperation

Joint Association Comments on CESR's call for evidence
Market Abuse Directive Adopted

Member States to transpose it by 12 October 2004

Drafting level 2 measures
Text of the proposal

ISDA's letter to the European Commission
Collateral Directive Adopted

Member States to transpose it by 27 December 2003

ISDA response to European Commission consultation on the evaluation of the implementation of the EU collateral directive (April 03, 2006)

Text of the directive

Status of implementation

Extension of Lamfalussy procedure to banking and insurance In discussion

Joint European Associations' Response to Lamfalussy Inter-Institutional Monitoring Group

ISDA's letter to the Economic and Financial Committee

UK FSA CP 153 on Alternative Trading Systems Provisions expected to take effect on 1 January 2004 CP 153

ISDA's response

Top of Page

 Last Updated: March 26, 2008