SUBMISSIONS DATED 2003

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY
12/12/2003 Clive Briault and Ian Tower, FSA ISDA/BBA/LIBA response to CP 189: Report and first consultation on the implementation of the new Basel and EU Capital Adequacy Standards.
12/10/2003 Mr. David Brown
Executive Director, USTA Project
Mr. Maxime Pare
Chair, CSA USTA Task Force		 ISDA submits a letter in support of proposed amendments to the Uniform Securities Transfer Act (the "USTA")
12/04/2003 The European Commission ISDA comments on EC's working document on second set of implementing measures of Market Abuse Directive
11/26/2003
 Ki Choon Kim at National Assembly of Republic of Korea; Ki Bae Lee at Ministry of Justice and Judge Hong Do Kim at Supreme Court of Korea
 ISDA comments on the introduction of a close-out netting provision as part of the proposed consolidated insolvency legislation in Korea
11/20/2003 Mr Fabrice Demarigny, Secretary General, CESR ISDA letter on CESR's "Draft Recommendation for Additional Guidance Regarding the Transition to IFRS"
11/20/2003 Sir David Tweedie, IASB, ISDA comments and recommendations on proposed hedge accounting effectiveness testing under IAS 39
11/11/2003 Ms. Sandra Thompson, IASB ISDA letter on the IASB's "macro hedging" proposal
11/11/2003 International Institute for the Unification of Private Law (Unidroit), Comments to the Unidroit Study Group on Harmonised Substantive Rules Regarding Securities Held with an Intermediary
11/04/2003 The Honorable Bill Frist and the Honorable Tom Daschle ISDA heads coalition opposing Feinstein/Lugar/Levin energy market amendment
11/03/2003 Norah Barger & Erik Heitfield, Federal Reserve Board Joint Trade Associations' comment letter on the FRB White Paper on Double Default and Double Recovery Effects
11/03/2003 Federal Reserve Board, OCC, FDIC
 Comment on U.S. Advance Notice of Proposed Rulemaking on the New Basel Accord
10/24/2003
 China Banking Regulatory Commission (CBRC)
 * ISDA comments on CBRC’s Consultative Draft of the "Administrative Rules on Financial Institutions Engaging in Derivative Transactions"
10/22/2003 EU Commission Services ISDA and LIBA respond to EU Commission consultation on the Risk Based Capital Directive (Annex 2, Annex 3)
10/10/2003 UK Treasury (HMT) ISDA responds to UK Treasury consultation on the implementation of the directive on financial collateral arrangements
10/01/2003 Monetary Authority of Singapore (MAS)
 * ISDA comments on MAS Draft Notice on Recognition of Bilateral Netting For Capital Adequacy
09/26/2003 Department of Treasury Letter on Taxation of Notional Principal Contracts that Provide for Contingent Payments
09/12/2003 European Commission DG Justice and Home Affairs Green Paper on the Conversion and Modernisation of the 1980 Rome Convention on the Law Applicable to Contractual Obligations
08/07/2003

 Bank of Thailand
 In September 03, Bank of Thailand ("BOT") issued a confirmation memo recognizing the ISDA Master Agreements as valid netting agreements according to the conditions in a recent BOT notification (No. 65-2546). (ISDA's letter, BOT memo)
08/04/2003 Internal Revenue Service Proposed Sec. 475 Book-Tax Conformity Safe Harbor (Exhibit A – ISDA Primary Members)
07/31/2003 Basel Committee on Banking Supervision Capital treatment of securitisation under Basel II
07/31/2003 United States District Court Southern District of New York Amicus Brief - Rate of Interest Under the ISDA Master Agreement (Finance One Public Company Limited v Lehman Brothers Special Financing, Inc.)
07/31/2003 Basel Committee on Banking Supervision, BIS ISDA and TBMA comment on the Third Consultative Paper (CP3) on the New Capital Accord
07/24/2003 Russian Federation State Duma Committee on Property, Chairman Victor S.Pleskachevsky MP ISDA comments on draft Federal Law on Derivatives
07/03/2003 French Ministry of Finance ISDA remarks on implementation debate in France of the Directive on Financial Collateral Arrangements
07/03/2003 British Insolvency Service ISDA comments on Draft Insolvency Amendment Rules 2003
06/25/2003 Models Task Force of the Basel Committee on Banking Supervision
 Joint ISDA/LIBA/TBMA recommendations on the counterparty risk treatment of OTC derivatives and securities financing transactions
(Counterparty Risk Recommendations, Counterparty Risk Annex)
06/06/2003 German Ministry of Justice ISDA comments on consultation document on implementation in Germany of the Directive on Financial Collateral Arrangements
05/16/2003 European Commission Principal Administrator DG Internal Market EU member states meeting on implementation of the collateral directive and ratification of the Hague convention on indirectly held securities
05/16/2003 European Commission ISDA's comments on Communication from the Commission to the European Parliament and the Council "A More Coherent European Contract Law - An Action Plan"
05/12/2003 Internal Revenue Service Suggested Anti-Abuse Rule for Use with the Wait-and-See Method of Accruing Contingent Payments on Notional Principal Contracts
05/07/2003 Energy White Paper ISDA highlights efforts to restore confidence in energy trading markets
05/07/2003 The Honorable Bill Frist and the Honorable Tom Daschle ISDA sends Feinstein Opposition Letter to Senate Staff
5/02/2003 Internal Revenue Service Notice 2003-26: Comments on Recommendations for the 2003-2004 Guidance Priority List - ISDA requests inclusion of guidance on the tax treatment of credit default swaps
04/29/2003 UK HM Treasury ISDA response to HMT paper "Directive on Financial Collateral Arrangements: Initial Policy and Legal Questions
04/28/2003 Ms. Sandra Thompson ISDA IASB Meeting April 8th, 2003
04/24/2003 UK HM Treasury Response to proposals for new powers to deal with major operational disruption to financial system
04/15/2003 USL Project Steering Committee of the Canadian Securities Administrators ISDA Comments on Concept Proposal for Uniform Securities Legislation as it concerns OTC derivatives.
04/09/2003 MAS Singapore, Market Conduct Policy Division ISDA submission regarding Monetary Authority of Singapore consultation on Hague Convention on Indirectly Held Securities
03/21/2003 European institutions ISDA's and other International and European association briefing paper on ISD2
03/19/2003 Norah Barger Letter to the Credit Risk Mitigation Sub-group on repo VaR multipliers.
03/03/2003 Fabrice Demarigny
 Committee of European Securities Regulators Preliminary observations on some aspects of the second call for evidence on implementation of the Market Abuse Directive
2/2003

David Wright

 Response to Commission Services' Working Document on Capital Requirements for Credit Institutions and Investment Firms
(Cover Letter, Response)
2/05/2003 Internal Revenue Service, Department of Treasury Additional Comments by ISDA Relating to the Tax Shelter Regulations Issued on October 22, 2002 and Amended by Notice 2003-11

1/31/2003 UK Financial Services Authority ISDA's response on CP153 - Alternative Trading Systems

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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.