SUBMISSIONS DATED 2005

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY
12/28/2005
Federal Energy Regulatory Commission (FERC)
ISDA Supplement to Reply Comments
12/05/2005
Federal Energy Regulatory Commission (FERC) (also refer to 12/28/05 submission)
ISDA Files Reply Comments
12/05/2005 Mr Demarigny, CESR (Committee of European Securities Regulators) ISDA Letter regarding CESR's Advice on Clarification of Definitions concerning Eligible Assets for Investments of UCITS - 2nd Consultation Paper
12/05/2005 Mr Rowe, Financial Services Authority ISDA Letter regarding FSA Discussion Paper on Trading transparency in the UK secondary bond markets
12/05/2005 Mr Demarigny, CESR (Committee of European Securities Regulators) Joint Association response to CESR Paper on Mediation Mechanism
12/01/2005
Bank Negara Malaysia
* ISDA submission on Netting in Malaysia
11/30/2005 Mr. Lawrence W. Smith
Director—Technical Application and Implementation Activities
FASB
Comment Letter on FIN 46(R) FASB Staff Position submitted to FASB on behalf of a joint industry working group consisting of ISDA ASF, TBMA, CMSA, and SIA
11/30/2005 Committee of European Banking Supervisors (CEBS)
ISDA-LIBA-BBA letter re CEBS Supplementary Note to Consultation Paper (CP) 07 on ECAIs' recognition
11/21/2005 Ms. Suzanne Q. Bielstein
Director – Major Projects and Technical Activities
Mr. Lawrence W. Smith
Director – Technical Application and Implementation Activities
Comments from ISDA, SIA and ASF in response to FASB's Working Draft of SFAS No. 15X, and proposed FSP No. FAS 133-a
11/17/2005 Federal Energy Regulatory Commission (FERC) (also refer to 12/05/05 & 12/28/05 submissions) ISDA files Submission with FERC on Market Manipulation
11/08/2005 Committee of European Banking Supervisors (CEBS) ISDA-LIBA-BBA letter re CEBS Consultation Paper (CP) CP09: Co-operation between Consolidating Supervisors and Host Supervisors
11/08/2005
State Administration of Foreign Exchange (SAFE), PRC
* ISDA submission on Inter-bank Foreign Exchange Market - RMB Forward Master Agreement
10/31/2005 Committee of European Banking Supervisors (CEBS)
ISDA-LIBA-BBA letter re CEBS Consultation Paper (CP) CP10: Guidelines on the implementation, validation and assessment of Advanced Measurement (AMA) and Internal Ratings Based (IRB) Approaches
10/31/2005 Prof Dr Arnold Schilder, Chairman of the Accounting Task Force, Basel Committee ISDA Letter on the Consultative Document “Supervisory guidance on the use of the fair value option by banks under International Financial Reporting Standards” published in July 2005
10/28/2005 Committee of European Banking Supervisors (CEBS)
ISDA-LIBA letter re CEBS Consultation Paper (CP) CP08 on its role and tasks
10/28/2005 Alan Texeira, Senior Project Manager, IASB ISDA Response Letter to IASB’s Exposure Draft of proposed changes to IFRS 3: Business Combinations
10/27/2005 FSA Potential regulatory issues around a) structured retail products and b) hedge funds
10/21/2005 Committee of European Banking Supervisors (CEBS)
ISDA/BBA/LIBA response on CEBS’ CP03: Application of the Supervisory Review Process Under Pillar 2 Revised
10/10/2005 Mr. Lawrence Smith
Director – Technical Application and Implementation Activities
Financial Accounting Standards Board
Comments from ISDA regarding Accounting for Certain Hybrid Financial Instruments an amendment of FASB Statements No. 133 and 140
10/07/2005 UK Department of Trade and Industry, Corporate Law and Governance ISDA comments on consultation regarding the registration of companies’ security interest (company charges)
09/30/2005 Committee of European Banking Supervisors (CEBS) Joint trade association response on CEBS' CP07 on the recognition of External Credit Assessment Institutions
09/22/2005 Linda MacDonald
Financial Accounting Standards Board
Comments from ISDA, SIA and ASF on Fair Value Measurements and Dealer Profit
09/14/2005 Ian Pickering, The Financial Services Authority ISDA comment letter regarding FSA Quarterly consultation (No.5)
09/08/2005

Committee on Banking, Housing and Urban Affairs United States Senate

Prepared Statement of Robert G. Pickel Executive Director and Chief Executive Officer International Swaps and Derivatives Association, Inc.

09/08/2005
China Banking Regulatory Commission Supervisory Rules and Regulations Department
* ISDA submission on Proposed Netting Rules
08/31/2005 Mr. Gilles Gauthier, Director -Industry Canada
Comment letter on Amendments to the Bankruptcy and Insolvency Act and Companies' Creditors Arrangement Act
08/05/2005 Lord Browne-Wilkinson, Chairman, Financial Markets Law Committee ISDA comments on FMLC Issue 8 (proposal relating to amicus briefs on practice in the wholesale financial markets)
08/01/2005 Dr Ishrat Husain, Governor, State Bank of Pakistan ISDA technical comments on proposed Netting of Financial Contracts Act (2005)
08/01/2005 European Commission, DG Internal Market ISDA comments on Green Paper on Financial Services Policy (2005-2010)
07/28/2005 Ms Davida Lachman-Messer, Deputy Attorney-General, Israeli Ministry of Justice ISDA comments on Draft Law on Financial Agreements
07/22/2005
Mr Shri R K Jain, Deputy Secretary Lok Sabha Secretariat Standing Committee on Finance Branch
* Comment Letter to PSC in response to Bill No. 76 of 2005 - The Reserve Bank of India (Amendment) Bill, 2005
07/11/2005 European Parliament and EU Commission Joint Associations Statement on the need for Comitology in the Capital Requirements Directive (CRD)
07/08/2005 Committee of European Banking Supervisors (CEBS) ISDA-BBA-LIBA letter re CEBS Consultation on financial reporting (CP06)
07/06/2005 United States Bankruptcy Court Southern District of New York Amicus Brief in Bear Stearns versus Enron Bankruptcy Litigation
06/29/2005 Committee of European Banking Supervisors (CEBS) ISDA-BBA-LIBA letter re CEBS Consultation on the framework for Supervisory Disclosure (CP05)
06/24/2005 The Secretary to the Code Committee; The Panel on Takeovers and Mergers ISDA® Comment Letter to the UK Takeover Panel (PCP 2005/2)
06/20/2005 Alan Napier, Department for Work and Pensions ISDA Comment Letter to Department for Work and Pensions on the draft Occupational Pension Schemes (Investment) Regulations 2005
06/14/2005
ISDA Members
Memo from Gide Loyrette Nouel on Redenomination of Romanian currency
06/09/2005 Mr Demarigny, CESR (Committee of European Securities Regulators) ISDA Comment Letter to CESR regarding CESR's Advice on Clarification of Definitions concerning Eligible Assets for Investments of UCITS
06/08/2005 Mr Damodaran, Chairman of Securities Exchange Board of India
* Request for Clarification of Disclosure Requirements applicable to Foreign Institutional Investors
05/31/2005 IASB ISDA Letter to IASB on IFRIC Draft Interpretation: Reassessment of Embedded Derivatives
05/27/2005 European Commission ISDA-FBE-LIBA Response to Commission Services Consultation Paper on Trading Activities Related Issues and the Treatment of Double Default Effects
05/27/2005 Svetlana Boysen, Project Manager, EFRAG ISDA Letter to EFRAG on IFRIC Draft Interpretation: Reassessment of Embedded Derivatives
05/27/2005 Basel Committee
Press Release; Joint Associations letter to the Basel Committee regarding the Application of Basel II to Trading Activities in the Trading Book Review
05/24/2005 Mr. John D.K. Lawrence Director Financial Services Commission ISDA Letter to the Financial Services Commission on Anguilla Netting legislation
04/08/2005 Andrea Pryde, IASB ISDA Letter to IASB on ED-7 "Financial Instruments: Disclosures" and new proposals around "day 1" profits
04/04/2005 CESR (Committee of European Securities Regulators) Joint Associations’ response to CESR consultation on best execution and market transparency
04/01/2005 Mr. John D.K. Lawrence Director Financial Services Commission ISDA Letter to the Financial Services Commission on Anguilla Netting legislation
03/31/2005 International Institute for Unification of Private Law (UNIDROIT) Preliminary Draft Convention of Harmonised Substantive Rules Regarding Indirectly Held Securities
03/24/2005 Herr Alexander Radwan, European Parliament ISDA/LIBA Letter to European Parliament on Amendments to Directive on Capital Requirements (Letter, Amendments)
03/14/2005 David Garlick, HM Customs & Excise ISDA Letter to HM Customs & Excise on VAT treatment of Swap Premia
03/14/2005
Indian Finance Minister Mr. P. Chidambaram and Governor of RBI Dr. Y. V. Reddy
ISDA expresses support for the legal & legislative reform suggested in the budget speech
03/09/2005 U.S. House Agriculture Subcommittee on General Farm Commodities and Risk Management. Testimony of Mr. Robert Pickel before the House Agriculture Subcommittee, on Reauthorization of the CFTC
03/08/2005 Securities and Exchange Commission (SEC)
ISDA comment letter to the SEC relating to a registration, disclosure and reporting regime for synthetic securities
03/03/2005 CESR (Committee of European Securities Regulators) Joint Associations response to CESR consultation on admission to trading
03/03/2005 Senate Leadership Industry Letter of Support for Bankruptcy Reform
02/28/2005 Securities and Futures Commission, Hong Kong
Review of the Disclosure of Interest Regime under Part XV of the SFO
02/28/2005 UK Panel on Takeovers and Mergers ISDA Comment Letter to the UK Takeover Panel (PCP 2005/1)
02/28/2005 Eidgenoessische Finanzverwaltung - Rechtsdienst ISDA comments on Swiss draft act on custody and transfer of indirectly held securities (in German)
02/28/2005 European Capital Markets Institute ISDA comments on ECMI project on the potential impact of the Hague Securities Convention
02/18/2005 CESR (Committee of European Securities Regulators) Joint Associations response to CESR consultation on professional client agreements
02/03/2005 Lord Browne-Wilkinson, Chairman, UK Financial Markets Law Committee ISDA comments on UK Financial Markets Law Committee (FMLC Issue No 3) paper on property interests in investment securities
01/28/2005 Joint Forum Paper on ‘Credit Risk Transfer’ ISDA submits comment on October 2004 regulators’ Joint Forum paper on ‘Credit Risk Transfer’, welcoming paper’s measured assessment of the benefits of CRT. (The Joint Forum paper is available at www.bis.org)
01/11/2005 Steven J. Murphy
Managing Director, Public Finance Ratings
Standard & Poor's
ISDA comments on S&P’s Debt Derivative Profiles of swaps associated with U.S. municipal debt issuance
01/07/2005 Central Bank of the United Arab Emirates; Bahrain Monetary Agency, Saudi Arabian Monetary Agency, Qatar Central Bank, Central Bank of Kuwait, Bank Negara Malaysia.

ISDA submissions on local regulatory treatment of OTC derivatives transactions documented under ISDA.

* Letter is available from isdaeurope@isda.org.

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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.