For Immediate Release, Tuesday, November 10, 2009

For More Information, Please Contact:

Cesaltine Gregorio, ISDA New York, +1 212-901-6019,

Deirdre Leahy, ISDA New York, +1 212-901-6021,

Donna Chan, ISDA Hong Kong, +852 2200 5906, 


ISDA Comments on Chairman Dodd’s Discussion Draft


NEW YORK, Tuesday, November 10, 2009 – In response to the Discussion Draft “Restoring American Financial Stability” proposed by Senate Committee on Banking, Housing and Urban Affairs Chairman, Chris Dodd, the International Swaps and Derivatives Association, Inc. (ISDA) today made the following comment:


“ISDA and the industry recognize the need to improve the regulatory framework to modernize and protect the integrity of the financial system,” said Robert Pickel, Executive Director and Chief Executive Officer, ISDA.


“Today there is a broad consensus amongst policymakers and the industry around the world on four initiatives that support this goal: Appropriate regulation for all financial institutions that may pose a systemic risk to the financial system; Stronger counterparty risk management (including clearinghouses); Improved transparency; And strong, resilient operational infrastructure.”


“ISDA and the industry have made significant progress in reducing risk in the privately negotiated derivatives business. Since March, approximately $3.5 trillion of credit default swaps (CDS) have been centrally cleared. Industry-wide compression or 'tear-up' efforts helped to significantly reduce the notional amount of CDS outstanding. The Big Bang Protocol has successfully settled more than 60 auctions globally since October 2008. And in its effort to improve transparency, ISDA is leading the development of trade repositories.”


“While significant progress is being made, ISDA and the industry remain concerned about key aspects of the legislative proposals that have been introduced. Preserving flexibility to tailor solutions to meet the needs of customers is essential. Efforts to mandate that privately negotiated derivatives business trade only on an exchange would reduce their availability. Banning naked shorting via CDS would adversely impact the credit markets. Cross-border regulatory coordination on these matters is imperative.”


About ISDA

ISDA, which represents participants in the privately negotiated derivatives industry, is among the world’s largest global financial trade associations as measured by number of member firms. ISDA was chartered in 1985, and today has over 830 member institutions from 58 countries on six continents. These members include most of the world’s major institutions that deal in privately negotiated derivatives, as well as many of the businesses, governmental entities and other end users that rely on over-the-counter derivatives to manage efficiently the financial market risks inherent in their core economic activities.  Information about ISDA and its activities is available on the Association's web site:


ISDA® is a registered trademark of the International Swaps & Derivatives Association, Inc.