ISDA Comment Letters, Policy Papers & Statements

SUBMISSIONS DATED 2011

SUBMISSION DATE	ADDRESSED TO	TOPIC SUMMARY
4/8/2011	CFTC	CFTC’s NPR: Processing, Clearing, and Transfer of Customer Positions
4/6/2011	Vladimir Milovidov, Head, Federal Service for Financial Markets in Russia, and Mr Vladislav Reznik, Chairman, Committee on Credit Organizations and Financial Markets, Russian Federation State Duma	ISDA comments on the introduction of netting provisions into Russian legislation
3/28/2011	National Bank of Romania - Financial Stability Department	ISDA comments on Draft Amendments to Romanian Implementation of EU Collateral Directive
3/21/2011	CFTC	CFTC’s NPR: Risk Management Requirements for Derivatives Clearing Organizations
3/9/2011	IASB (International Accounting Standards Board)	ISDA's Comment Letter on the IASB's Exposure Draft ED/2010/13 - Hedge Accounting
3/8/2011	European Commission	ISDA’s Comments on the Commission Communication on Challenges in Commodity Markets and on Raw Materials
3/8/2011	CFTC	CFTC’s NPR: Core Principles and Other Requirements for Swap Execution Facilities
3/8/2011	Reserve Bank of India	* ISDA submission on Draft Guidelines on Credit Default Swaps (CDS) for Corporate Bonds
3/7/2011	CFTC	CFTC’s NPR: Governance Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities; Additional Requirements Regarding the Mitigation of Conflicts of Interest
3/3/2011	European Commission – DG Internal Market and Services	ISDA responds to EU consultation on bank recovery and resolution
2/28/2011	CFTC	CFTC’s NPR: Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements
2/22/2011	SEC	SEC’s Proposed rule: Trade Acknowledgment and Verification of Security-Based Swap Transactions
2/22/2011	CFTC & SEC	CFTC & SEC’s Joint Proposed Rule: Further Definition of “Swap Dealer,” “Security-Based Swap Dealer,’’ “Major Swap Participant,” “Major Security-Based Swap Participant’’ and “Eligible Contract Participant”
2/17/2011	CFTC	CFTC’s Notice of Proposed Rulemaking: Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties
2/14/2011	SEC	SEC’s Notice of Proposed Rulemaking: Process for Review of Security-Based Swaps for Mandatory Clearing
2/11/2011	UK Ministry of Justice, Ms Jean McMahon	ISDA response to the UK consultation on the opt-in to the revised EU Brussels 1 Regulation on Jurisdiction, Recognition and Enforcement of Judgments in Civil and Commercial Matters
2/11/2011	CFTC	CFTC’s Proposed Rulemaking regarding General Regulations and Derivatives Clearing Organizations
2/7/2011	CFTC	CFTC’s Proposed Rulemaking on: 1) 17 CFR Part 43 Real-Time Public Reporting of Swap Transaction Data; 2) 17 CFR Part 45 Swap Data Recordkeeping and Reporting Requirements; and 3) 17 CFR Part 23 Reporting, Recordkeeping, and Daily Trading Records Requirements for SDs and MSPs.
2/1/2011	CFTC	CFTC’s Proposed Rulemaking on the Protection of Collateral of Counterparties to Uncleared Swaps
1/31/2011	MiFID CG	ISDA’s response to the European Commission’s Public Consultation on the Review of the Markets in Financial Instruments Directive (MiFID)
1/31/2011	European Commission DG Justice	ISDA responds to Commission Green Paper on European Contract Law
1/31/2011	ISDA Members	IASB/FASB - Exposure Draft on Offsetting Financial Assets and Financial Liabilities
1/31/2011	IASB (International Accounting Standards Board)	ISDA's Comment letter on te IASB's Request for Views on "Effective Dates and Transition Methods”
1/24/2011	CFTC	CFTC’s Proposed Rules Regarding Registration of Swap Dealers and Major Swap Participants
1/21/2011	European Commission DG-General Internal Markets and Services	Consultation on EU Securities Law Directive
1/20/2011	FSOC	Financial Stability Oversight Council’s (FSOC’s) Advance Notice of Proposed Rulemaking: Authority to Designate Financial Market Utilities as Systemically Important
1/18/2011	CFTC	CFTC’s Proposed Regulations Regarding Protection of Cleared Swaps Customers Before And After Commodity Broker Bankruptcies
1/18/2011	SEC	SEC’s Proposed Regulations Regarding Regulation SBSR - Reporting and Dissemination of Security-Based Swap Information (Click here for the Study)
1/18/2011	CFTC	CFTC’s Implementation of Conflicts of Interest Policies and Procedures by Futures Commission Merchants and Introducing Brokers
1/14/2011	China Banking Regulatory Commission	* JAC submission on the draft Regulations governing Sales of Wealth Management Products by Commercial Banks
1/14/2011	Autorité des marchés financiers (AMF) & Ontario Securities Commission	Canadian Securities Administrators' (CSA) Consultation Paper on Over-the-Counter Derivatives Regulation in Canada (CSA Consultation Paper)
1/11/2011	CFTC	ISDA/SIFMA Pre-Comment on Position Limits
1/11/2011	CFTC & SEC	CFTC/SEC’s Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities Regarding the Mitigation of Conflicts of Interest & Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges With Respect to Security-Based Swaps under Regulation
1/3/2011	CFTC	CFTC’s ANPR regarding Antidisruptive Practices Authority Contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act

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* These particular submissions are not available to the general public, however, they may be made available to member firms/institutions of ISDA. If you are a member and require a document which is not available, please send an email to ISDA@ISDA.ORG stating the submission date and topic summary of the document you require.