SUBMISSIONS DATED 2004

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY
12/23/2004 EU Emissions Trading Scheme Unit, UK Dept for Environment, Food and Rural Affairs (DEFRA) ISDA comments on DEFRA consultation on EU Emissions Trading Scheme regarding insolvency treatment of emissions allowances under English law
12/20/2004 United States Court of Appeals for the Second Circuit Amicus Brief - Bankruptcy Administrator for Jugobanka v Superintendent of Banks of the State of New York
12/13/2004 Mrs Davida Lachman-Messer, Deputy Attorney-General, Economic & Fiscal Matters, Israeli Ministry of Justice and Mr Yoav Lehman, Supervisor of Banks, Bank of Israel. Netting amendments to Israeli insolvency law
12/10/2004 ISDA Members
 Memo on Redenomination of Turkish Lira
12/09/2004 Jaime Caruana, Basel Committee Joint ISDA-FBE-IIF-LIBA-TBMA letter to Basel Committee regarding the timescales given for different issues covered in the Trading Book Review
11/24/2004 Mr Oleg Vyugin, Head of the Russian Federal Service for Financial Markets Russian derivatives legislation
11/23/2004 The UK Law Commission ISDA Comments on Consultative Report (Consultation Paper No 176): Company Security Interests
10/22/2004 Andrea Pryde, IASB ISDA comment letter to IASB on ED-7 Disclosures for Financial Instruments
10/13/2004 Department of the Treasury and the Internal Revenue Service Comments on Proposed Regulations Relating to Notional Principal Contracts with Contingent Nonperiodic Payments
10/08/2004 Sandra Thompson, IASB ISDA comment letter to IASB on Amendments to IAS 39: Cash Flow Hedge Accounting of Forecast Intragroup Transactions
10/08/2004 Sandra Thompson, IASB ISDA comment letter to IASB on Amendments to IAS 39: Transition and Initial Recognition of Financial Assets and Financial Liabilities
10/08/2004 Andrea Pryde, IASB ISDA comment letter to IASB on Amendments to IAS 39 & IFRS 4: Financial Guarantee Contracts and Credit Insurance
10/04/2004 Informal ISDA Paper for discussion on Regulations vs Directives ISDA paper discussing Regulations vs Directives implementing measures in regard to the Directives on Markets in Financial Instruments (MiFID)
09/21/2004 Shri Surinder Kumar Watts, Parliament of India, Rajya Sabha Secretariat * Proposed Arbitration and Conciliation (Amendment) Bill, 2003
09/15/2004 Jonathan G. Katz, Securities and Exchange Commission ISDA comments to SEC on proposed registration of hedge funds
09/3/2004 International Institute for the Unification of Private Law (Unidroit); ISDA comments on Preliminary Discussion Draft Convention on Substantive Rules Regarding Securities Held with an Intermediary
09/2/2004 Suzanne Q. Bielstein
Financial Accounting Standards Board
 Joint Working Group of ISDA, TBMA & SIA comments on Financial Accounting Standards Board's ("FASB") Exposure Draft (the "Exposure Draft"), Fair Value Measurements
08/31/2004 Louis Roldan, CEBS (Committee of European Banking Supervisors)
 Joint Industry Association Response to CEBS' (Committee of European Banking Supervisors) Paper on the Supervisory Review Process (Pillar 2), from ISDA, LIBA and the BBA
08/31/2004 European Commission, DG Markt. ISDA comments on Communication dated 28 April 2004 from the Commission to the Council and European Parliament entitled "Clearing and Settlement in the European Union - The Way Forward"
08/31/2004 Ms. Brenda Benham
British Columbia Securities Commission		 Comment Letter on the draft rules under the British Columbia Securities Act, S.B.C. c.43.
08/20/2004 Ministry of Law and Justice
Justice Saraf Committee on Arbritration, India 		* Proposed Arbitration and Conciliation (Amendment) Bill, 2003
08/13/2004 Jonathan G. Katz - Securities and Exchange Commission Request for extension of deadline for comment on SEC Hedge Fund Proposal
08/09/2004 Nick Le Pan, Accord Implementation Group (AIG) Joint ISDA-LIBA-BBA working group paper on Low Default Portfolios (Introductory Paper, Paper)
07/28/2004
 Finance and Economy Committee of the National People's Congress - Legal Committee
 * ISDA letter on The Draft Enterprise Insolvency Law
07/26/2004 Commissioner Frits Bolkestein, Directorate-General Internal Market, European Commission The Hague Convention on the Law Applicable to Certain Rights in Respect of Securities Held with an Intermediary
07/22/2004
 China Banking Regulatory Commission (CBRC) Supervisory Rules and Regulation Department
 * ISDA letter on the New Derivative Product Approval and Publicity of Information on Derivative Licence Holders
07/21/2004 United States Bankruptcy Court Southern District of New York Amicus Brief - Safe Harbor Provisions under the U.S. Bankruptcy Code (Enron Corp. v UBS)
07/21/2004 Sandra Thompson, IASB ISDA Comment letter on the IASB's ED on IAS 39 and the Fair Value Option
07/19/2004
Federal Reserve, OCC, FDIC, OTS and SEC Industry Response to Interagency Statement on Complex Structured Finance Transactions (press release) (comment letter)
07/15/2004 ISDA Technical Paper prepared by Freshfields on the EU Insolvency Regulation (cover note)(paper)
07/09/2004 Richard Thomas, Inland Revenue ISDA letter to Inland Revenue on the latest draft of the Disregard Regulations
07/02/2004 Patrick Mommens, EFRAG Secretary General ISDA letter to EFRAG on their preliminary view's on the IASB's fair value option exposure draft
06/28/2004 Wayne Upton, Director of Research, IASB ISDA nominations to the IASB Financial Instruments Working Group
06/25/2004 Mr. Lawrence W. Smith, Financial Accounting Standards Board ISDA Comments on EITF Issue No. 04-7, "Determining Whether an Interest is a Variable Interest in a Variable Interest Entity"
06/25/2004 Ms Andrea Pryde, IASB ISDA Letter to IASB regarding Strengthening the IASB's Deliberative Procedures
06/09/2004 ISDA members US Exchanges and Market Closings on June 11, 2004
06/07/2004 Norah Barger, Basel Committee Joint ISDA-LIBA-TBMA Letter on the capital treatment of unsettled transactions
06/07/2004
 Mr. Gilles Gauthier, Director - Industry Canada

ISDA Comments on the Bankruptcy and Insolvency Act, Companies' Creditors Arrangement Act, and Winding-up and Restructuring Act
05/19/2004 U.S. Court of Appeals for the Second Circuit Amicus Brief in connection with Finance One Public Company Limited v. Lehman Brothers Special Financing, Inc.
05/19/2004
  • Charles Grassley, Chairman, Senate Finance Committee and Max Baucus, Ranking Member, Senate Finance Committee
  • Bill Thomas, Chairman, Ways and Means Committee and Charles Rangel, Ranking Member, Ways and Means Committee
ISDA urges the Senate Finance Committee and House Ways and Means Committee to preserve current law "qualified covered call" (QCC) treatment for OTC options. ISDA letter to US Senate. ISDA letter to US House of Representatives. Memo on Qualified Covered Calls.
05/18/2004 Mr Robert H. Herz, Chairman, Financial Accounting Standards Board
 ISDA Comments on FASB Statement 133 Implementation Issue No. D1, Application of Statement 133 to Beneficial Interests in Securitized Financial Assets
05/11/2005 Jaime Caruana, Basel Committee ISDA/EBF letter sent simultaneously with IIF, regarding Treatment of Loss Given Default
05/10/2004 Ms. Jane Brindle, Legal Counsel Alberta Canadian Securities Administrators Comment Letter on the Uniform Securities Act and the Model Securities Administration Act
04/23/2004 National authorities in certain OAS member states Proposed Inter-American Treaty to Modernize Securities Ownership, Transfer and Pledging Legal Framework. ISDA submitted a letter in English, and Spanish or Portuguese (as applicable) to various members of the Organization of American States (OAS), expressing support for a drafting effort being undertaken by the National Law Center for Inter-American Free Trade.
04/08/2004 EU member states and accession countries Ministries of Finance The Risk Based Capital Directive - The Concerns of the Commodity Industry
04/07/2004
United States Bankruptcy Court Southern District of New York Amicus Brief - Safe Harbor Provisions under the U.S. Bankruptcy Code (Enron Corp. v CSFB Int'l and CSFB LLC)
03/31/2004 Mr Robert H. Herz, Chairman, Financial Accounting Standards Board ISDA Comments on the Revision to FASB Interpretation No. 46, Consolidation of Variable Interest Entities, ("FIN 46R")
1. ISDA Paper - Analyzing Derivatives Instruments under FIN 46R
2. Appendix A
03/31/2004 ISDA Study Examines Concentration of Credit Risk Among Major Derivatives Dealers Counterparty Risk Concentration Study 3-30-04
03/25/2004 United States Bankruptcy Court Southern District of New York Amicus Brief - Safe Harbor Provisions under the U.S. Bankruptcy Code (Enron Corp. and Enron North America Corp. v Bear Stearns International, Ltd. and Bear Stearns Securities Corp.)
03/19/2004 Department of the Treasury and the Internal Revenue Service Request for Clarification of Effective Date Statements in Preamble to Proposed Regulations on Notional Principal Contracts with Contingent Nonperiodic Payments
03/17/2004 United States Bankruptcy Court Southern District of New York Amicus Brief - Safe Harbor Provisions under the U.S. Bankruptcy Code (Enron Corp. v Lehman Bros. Fin. S.A.)
03/12/2004 Norah Barger, Chair of Credit Risk Mitigation Sub-group of the Basel Committee ISDA response to the Credit Risk Mitigation Sub-group of the Basel Committee on the treatment of Restructuring Risk
03/12/2004 Mr Robert H. Herz, Chairman, Financial Accounting Standards Board ISDA Comments on FASB Statement 133 Implementation Issue No. D1 and the finalization of IASB Statement No. 39
03/09/2004 EU Commission DG Justice and Home Affairs ISDA comments on Commission consultation regarding draft Hague Convention on Choice of Courts Agreements
03/04/2004 European Commission ISDA-LIBA Response to European Commission consultation on the Treatment of CIUs in the Trading Book and Banking Book
03/01/2004 HM Treasury Banking and General Insurance Team ISDA response to UK consultation and implementation of the Credit Institutions Reorganisation and Winding Up Directive
02/25/2004 National Association of Insurance Commissioners
 ISDA Comment Letter on NAIC's draft white paper entitled, "Weather Financial Instruments (Temperature): Insurance or Capital Markets Products?".
02/16/2004 Mr Quentin Lloyd, Financial Services Authority Joint ISDA-BBA-LIBA letter to FSA on securitisation
02/13/2004 Pierre Delsaux, Chairman, Expert Group on Securities, DG Internal Market, European Commission; ISDA submission to Expert Group on Securities - Harmonisation of netting
02/11/2004 Mr Tom Seidenstein, Director of Operations and Secretary, IASC Foundation ISDA representation on Identifying Issues for the IASC Foundation Constitution Review
02/10/2004 Mr Kunle Ogundele, Inland Revenue ISDA's representations on Proposed New Approach to the Taxation of Derivatives Based on Property and Share Values
02/04/2004 U.S. Securities and Exchange Commission Capital standards for Investment Bank Holding Companies and Consolidated Supervised Entities; Appendices
01/12/2004 Mr Fabrice Demarigny, Secretary General, CESR ISDA's comments on the Draft No 2 On Financial Information Coordination of Enforcement Activities (Ref: CESR/ 03-317b)
01/12/2004 Paul Rutteman, EFRAG Secretary General ISDA's proposal for a Financial Instruments Sub-committee of EFRAG
01/06/2004 National Association of Insurance Commissioners ISDA Letter of Intent to the National Association of Insurance Commissioners

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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.