SUBMISSIONS DATED 2006

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY
12/29/2006
ISDA members
US Exchange Closings on January 2, 2007
12/27/2006
Securities and Exchange Commission
Regulation AB, Item 1115
12/21/2006 The Bank of Thailand
* ISDA submission on Notification of Reserve Requirements
12/08/2006
Mr. Larry Smith
Director – Technical Application and Implementation Activities
FASB
ISDA and ASF are pleased to offer the following comments in response to the Financial Accounting Standards Board’s (“FASB”) Proposed Statement 133 Implementation Issue No. B40, Embedded Derivatives: Application of Paragraph 13(b) to Securitized Interests in Prepayable Financial Assets, (“Proposed Issue B40”).
11/30/2006 New Zealand Ministry of Economic Development
ISDA Letter on Review of Securities Offerings Discussion Document Relating to the Definition of “Derivative” (Letter) (Appendix)
11/03/2006 IASB (International Accounting Standards Board) ISDA letter on the IASB and FASB Joint Conceptual Framework for Financial Reporting Preliminary views paper
10/23/2006 Accord Implementation Group IIF-ISDA-LIBA Note to the Accord Implementation Group regarding Strand Three of the Trading-Book Review
10/23/2006 IASB (International Accounting Standards Board) ISDA response to proposed amendments to IAS 32
10/06/2006 Institute for the Unification of Private Law (UNIDROIT) ISDA proposals to amend UNIDROIT draft convention on harmonised substantive rules for intermediated securities
10/02/2006 Committee of European Banking Supervisors (CEBS) ISDA-LIBA-BBA response on CEBS CP12 on Stress Testing under the Supervisory Review Process
09/21/2006 ISDA from Commission Bancaire Commission Bancaire's response to ISDA's February 17th letter on the recognition of purchased CDS protection documented under a Master netting agreement
09/18/2006 Sir David Tweedie, Chairman of IASB Industry comments on the importance of a global fair value measurement standard
09/15/2006 European Commission, Internal Markets and Services DG
Responses to EC Call for Evidence on transparency provisions in MiFID. ISDA response. Joint industry response.
09/15/2006 European Commission, DG Internal Markets and Services Additional ISDA Remarks Concerning the Evaluation of the Implementation of the EU Collateral Directive
08/22/2006 ISDA Members and Non-Members
Memo on migration of rate sources from Telerate to Reuters and implications for the 2000 ISDA Definitions
08/21/2006
Ms. Eileen Donovan, Acting Secretary, CFTC
ISDA comment letter responding to request for comments issued by the CFTC regarding possible changes to the CFTC’s Commitment of Traders report
08/21/2006 CEBS; EU Commission; UK FSA; and UK HMT ISDA-LIBA-BBA Industry report on Managing Concentration Risk. The review is based on 11 detailed responses to CEBS questionnaire on Large Exposures from large internationally active firms and submitted to the associations in confidence
08/18/2006 FSA (Financial Services Authority) Joint trade associations' response to FSA CP06/9
08/15/2006 CESR (Committee of European Securities Regulators) ISDA-BBA-LIBA response to the CESR questionnaire on the day-to-day application of the IOSCO Code by the Credit Rating Agencies
08/03/2006
Reserve Bank of India
* ISDA submission on Enactment of Reserve Bank of India (Amendment) Act, 2006
07/28/2006 Mr. David R. Bean
Director – Research and Technical Activities
Governmental Accounting Standards Board
The Bond Market Association (“TBMA”) and the International Swaps and Derivatives Association (“ISDA”) offered comments in response to the Governmental Accounting Standards Board’s (“GASB” or “Board”) Preliminary Views document on major issues related to Accounting and Financial Reporting for Derivatives (the “Preliminary Views document”). TBMA and ISDA highlight the importance of issuing standards that improve the usefulness of financial reports based on the needs of the report users, as well as the need to balance costs and benefits of new standards.
07/25/2006 Pakistan Banking Association ISDA technical comments on Draft Banking Act, 2006
07/13/2006
Bank Negara Malaysia
* ISDA submits detailed suggestions on how to improve legal and regulatory certainty related to close-out netting in Malaysia
06/29/2006 CP06/4 – Implementation of the Transparency Directive ISDA submits response on UK disclosure of cash-settled derivatives (FSA consultation CP06/4 on implementation Transparency Directive)
06/15/2006 Task Force on the Interagency Statement on Complex Structured Finance Transactions
ISDA, BMA and SIA send letter to financial regulators regarding interagency guidance on Complex Structured Finance Activities
06/08/2006 The Securities and Exchange Commission ISDA, TBMA and ASF submit letter to SEC on disclosure required under Items 1115 and 1114 of Regulation AB
06/08/2006 Chairmen of the Russian State Duma Committee on Credit Organizations and Financial Markets ISDA Comments on Draft Article 1062 of Russian Civil Code
05/31/2006 Banca d'Italia Implementation of the New International Prudential Framework (Basel II, the New Accord and New EU Directive on capital requirements for credit institutions and investment firms); discussion of distinction between close-out netting and set-off
05/19/2006 Peter Martin, Canadian Accounting Standards Board ISDA response to the Discussion Paper on Measurement Bases for Financial Accounting - Measurement on Initial Recognition
05/08/2006 United States Court of Appeals for the Second Circuit Amicus Brief - Aon Financial Products and Aon Corporation v Societe Generale
05/05/2006 Diane Moore, Financial Services Authority Joint Associations' response to FSA on CP06/3 - Strengthening Capital Standards
04/24/2006 Mr Demarigny, CESR (Committee of European Securities Regulators) Joint Associations response to CESR Call for evidence on Consolidation of Market Transparency Data
04/05/2006 Mr. Larry Smith
Director – Technical Application and Implementation Activities
FASB
ISDA, SIA, ASF and TBMA are pleased to offer the following comments in response to the FASB’s Proposed Statement of Financial Standards, The Fair Value Option for Financial Assets and Financial Liabilities (the “Exposure Draft”)
04/03/2006 European Commission, DG Internal Market and Services ISDA response to Commission questionnaire on the evaluation of the implementation of the Directive on Financial Collateral Arrangements
03/31/2006
China Foreign Exchange Trade System and State Administration of Foreign Exchange, PRC * ISDA submission on CFETS/SAFE draft Inter-bank RMB / FX Forward Master Agreement
02/28/2006 Mr Brian Penn, Esq, HM Courts Service, Civil Law and Justice Division. ISDA Remarks on European Commission Proposal for a Regulation on the Law Applicable to Contractual Obligations (Rome I Regulation)
02/27/2006 International Institute for the Unification of Private Law (UNIDROIT) ISDA Comments on Preliminary Draft Convention on Harmonised Substantive Rules Regarding Intermediated Securities
02/24/2006 Basel Committee on Banking Supervision ISDA/BBA/LIBA response to BCBS Consultation Document on Home-Host information sharing for effective Basel II implementation
02/17/2006 Guillaume Tabourin and Philippe Troussard at Commission Bancaire ISDA letter to Commission Bancaire on the recognition of purchased CDS protection documented under a Master netting agreement
02/17/2006 Ms Davida Lachman-Messer, Adv., Dep Attorney General, Israeli Ministry of Justice ISDA comments on proposed Law on Financial Asset Agreements, 5766-2005
02/16/2006 Committee of European Banking Supervisors (CEBS) ISDA-LIBA-BBA-ESF letter re CEBS Consultation Paper (CP) CP10R: Second Round of Consultation on the Validation and Assessment of Credit and Operational Risk Approaches under the Basel 2 regulatory Capital Requirements Directive
02/1/2006
Hong Kong Monetary Authority
* ISDA submission on proposals concerning bilateral netting agreements in the December 2005 Consultation Papers on New Capital Adequacy Standards in Hong Kong
01/31/2006 Ministry of Justice, South Korea
* ISDA submission on Presidential Decree under Article 120, Paragraph 3 of the Debtor Rehabilitation and Bankruptcy Law
01/30/2006 National Association of Insurance Commissioners ISDA Submits Comment Letter to NAIC on Accreditation for Close-out Netting Provisions Relating to Insurance Companies
01/27/2006
The Secretary to the Code Committee; The Panel on Takeovers and Mergers
ISDA Comment Letter to the UK Takeover Panel (PCP 2005/3 and 2005/4)
01/25/2006
Monetary Authority of Singapore
* ISDA submission on Consultation Paper on Recognition of Bilateral Netting for Capital Adequacy Purposes

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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.