SUBMISSIONS DATED 2009

SUBMISSION DATE ADDRESSED TO TOPIC SUMMARY

12/31/2009

Basel Committee on Banking Supervision – Cross-Border Bank Resolution Group

ISDA responds to report and recommendations on cross-border bank resolution

12/22/2009

Slovak Republic  - Ministry of Finance; Ministry of Justice and National Bank of Slovakia

ISDA submission in support of reform of netting and collateral legislation in Slovakia

12/21/2009

Chairman Baucus and Ranking Member Grassley

Final ISDA Letter on Extenders Bill for Distribution (ISDA Comments section 501 of FATCA) (Letter on Extenders Bill)

12/15/2009

Reserve Bank of India

* ISDA submission on Draft Comprehensive Guidelines on Foreign Exchange Derivatives and Hedging Commodity Price Risk and Freight Risk Overseas

12/14/2009

Financial Supervisory Service

ISDA submission regarding Risk Management Guidelines for FX Derivatives Transactions

11/30/2009

IASC Foundation

“Part 2 of the Constitution Review / Proposal for Enhanced Public Accountability”

11/20/2009

Republic of Ireland Department of Finance

Further ISDA submission regarding partial property transfer powers under the NAMA Bill 2009

11/20/2009

House Ways and Means Select Revenue Measures Subcommittee

The imposition of U.S. withholding tax with respect to certain payments made on equity swaps
(Exhibit to ISDA Letter) (ISDA Comments section 501 of FATCA)

11/6/2009

Central Bank of Chile

ISDA Comments on close-out netting in Chile

10/30/2009

Republic of Ireland - Department of Finance

ISDA comments on National Asset Management Agency Bill 2009

10/30/2009

Slovenian Ministry of Justice

Achieving legal certainty for close-out netting in Slovenia

10/21/2009

European Commission, European Parliament, Council of the European Union

ISDA comment on Proposal for a Directive on Alternative Investment Fund Managers (AIFMD)

10/9/2009

Russell Golden, FASB

Proposed Accounting Standards Update to Topic 820, Improving Disclosures about Fair Value Measurements

10/6/2009

Committee of European Securities Regulators

Final ISDA response to CESR consultation on classification and identification of OTC derivative instruments for the purpose of the exchange of transaction reports

9/28/2009

IASB (International Accounting Standards Board)

ISDA's Comment letter on the IASB's Exposure Draft on 'Fair Value Measurement"

9/18/2009

The National Assembly of Republic of Korea

ISDA submission to the National Assembly of Republic of Korea regarding the proposed new product approval bill

9/16/2009

UK Insolvency Service – Policy Unit

ISDA response to consultation on new UK regime for company rescue

9/14/2009

IASB (International Accounting Standards Board)

ISDA's Comment letter on the IASB's Exposure Draft  on “Financial Instruments: Classification and Measurement"

9/11/2009

Taiwan Financial Services Roundtable (TFSR)

* JAC acknowledgment letter to the Taiwan Financial Services Roundtable

9/3/2009

European Commission

Commodity Derivatives Working Group response to EC Derivatives consultation

9/3/2009

European Commission

European Commission second Stakeholders’ meeting in Brussels on IAS 39

9/1/2009

IASB (International Accounting Standards Board)

ISDA's Comment letter on IASB's Discussion Paper on " Credit Risk in Liability Measurement"

8/11/2009

Taiwan Financial Services Roundtable (TFSR) and the Financial Supervisory Commission (FSC)

* JAC submission regarding the draft rules issued by TFSR in respect of offshore structured notes

8/11/2009

The Australian Government

* ISDA submission on Improving Australia's Framework for Disclosure of Equity Derivative

7/10/2009 HM Treasury – Investment Bank Insolvency 3/09 ISDA response to HMT consultation on developing effective resolution arrangements for investment banks
7/8/2009 Ukrainian Parliament - Chairman of the Committee on Finance and Banking Derivatives legislation in Ukraine
7/8/2009 Russell Golden, FASB Proposed FASB Staff Position FAS 157-g, Estimating the Fair Value of Investments in Investment Companies That Have Calculated Net Asset Value per Share in Accordance with the AICPA Audit and Accounting Guide, Investment Companies
6/30/2009 European Commission –DG Justice, Freedom and Security – Unit Civil Justice ISDA responds to Commission Green Paper and Report on the review of the EU Regulation on Jurisdiction, Recognition and Enforcement of Judgments in Civil and Commercial Matters (Brussels 1 Regulation)
6/23/2009 European Commission DG Internal Market and Services ISDA response to consultation on legislation on legal certainty of securities holding and dispositions
6/19/2009 Elizabeth Murphy, U.S. Securities and Exchange Commission ISDA Comments on Proposed Amendments to Regulation SHO
6/18/2009 David Cook, UK Financial Services Authority ISDA Response to The Turner Review: “A regulatory response to the global banking crisis” & Discussion Paper 09/2: “A regulatory response to the global banking crisis”
6/16/2009 European Commission Commodity Derivatives Working Group (CDWG) response to EC Call for Evidence on Market Abuse Directive review. Note: the CDWG represents the views of commodity firm members of ISDA, the FOA and EFET, and has served, for several years, as a forum for commodity firms to engage with policymakers on issues pertaining to financial regulation of commodity firms.
6/16/2009 Commodity Futures Trading Commission ISDA submission Concept Release regarding Bona Fide Hedge Exemptions: 74 Red. Reg. 12282 (March 24, 2009)
6/15/2009 UK Financial Services Authority LIBA-ISDA-SIFMA-ISLA response to FSA CP 09/15 on short selling disclosure regime
6/15/2009 IOSCO ASF-ESF-ISDA-SIFMA response to IOSCO paper on unregulated markets and products
6/11/2009 European Commission LIBA-ISDA-SIFMA-ISLA response to EC Call for Evidence on Market Abuse Directive review (Call for Evidence) (Response)
6/4/2009 IASB (International Accounting Standards Board) ISDA's letter to the IASB on the IAS 39 replacement project
6/3/2009 Corporations and Financial Services Division
The Treasury
 ISDA submission on Margin lending provisions - Corporations Legislation Amendment (Financial Services Modernisation) Bill 2009
6/1/2009 Russell Golden, FASB Proposed FASB Staff Position FAS 157-f, Measuring Liabilities under FASB Statement No. 157
5/29/2009 European Commission Letter from Commodity Derivatives Working Group to European Commission on central clearing of commodity derivatives.  Note: the CDWG represents the views of commodity firm members of ISDA, the FOA and EFET, and has served, for several years, as a forum for commodity firms to engage with policymakers on issues pertaining to financial regulation of commodity firms
5/27/2009 The Australian Consumer Law
Competition and Consumer Policy Division
The Treasury
* ISDA submission on draft provisions of unfair contract terms - Trade Practices Amendment (Australian Consumer Law) Bill 2009
5/22/2009 NCOIL Model Legislation ISDA Comments on Proposed NCOIL Legislation for Credit Default Swaps
4/29/2009 Director Elemér Tertak, European Commission Joint Association (ISDA, LIBA, EBF, ESF) response to the EU Commission Services Working Document on proposed changes to the Capital Requirements Directive
4/23/2009 Market Conduct Policy Division
Capital Markets Department
Monetary Authority of Singapore
* ISDA submission on MAS Consultation Paper on Review of the Regulatory Regime Governing the Sale and Marketing of Unlisted Investment Products
4/22/2009 Basel Committee on Banking Supervision Joint Association (IBFED, ISDA, LIBA, ESF) response to Basel Committee on BCBS 150 - Proposed enhancement to the Basel II framework (Covering letter) (Response)
4/21/2009 CESR-ESCB ISDA response to consultation on draft Recommendations for CCPs including CCPs clearing OTC derivatives

4/17/2009

The Secretary for Financial Services and the Treasury; Securities and Futures Commission and Hong Kong Monetary Authority

* ISDA submission on the regulatory changes proposed in the SFC and HKMA Lehman Minibonds reports
4/17/2009 IASB (International Accounting Standards Board) ISDA's Comment letter on "IASB's request for views on the FASB's FSP FAS 157-4"
4/17/2009 IASB (International Accounting Standards Board) ISDA's Comment letter on "IASB's request for views on the FASB's FSP FAS 115-2 and 124-2”
4/10/2009 US House of Representatives – Committee on Agriculture ISDA response to questionnaire on climate change options to reduce greenhouse gas emissions
4/3/2009 IASC Foundation ISDA's Comment letter on “IASC Foundation Review of the Constitution: Identifying Issues for Part 2 of the Review”
4/2/2009 FCAG (Financial Crisis Advisory Group) ISDA's Comment letter on “Financial Crisis Advisory Group (FCAG) Written Submissions from Constituents”
3/27/2009 Russell Golden, FASB ISDA Comments on Proposed FASB Staff Position FAS 115-a, FAS 124-a, and EITF 99-20-b, Recognition and Presentation of Other-Than-Temporary Impairments
3/27/2009 Russell Golden, FASB ISDA Comments on Proposed FASB Staff Position FAS 157-e, Determining Whether a Market Is Not Active and a Transaction Is Not Distressed
3/13/2009 Klaas Knot, Basel Committee Joint Association (ISDA, LIBA, IBFed) response to “Principles for sound stress testing practices and supervision” (CP147)
3/13/2009 Basel Committee Joint Association (ISDA, IIF, LIBA, IBFed) response to “Revisions to the Basel II market risk framework" (BCBS 148) and "Guidelines for computing capital for incremental risk in the trading book" (BCBS 149)
3/5/2009 FSA Joint Association (ISDA, LIBA, BBA) response to the UK FSA's CP 08 22 on "Strengthening Liquidity Standards"
2/27/2009

UK HMT -Team Leader - Financial Stability/Banking Reform

ISDA comments on UK Banking Act 2009 – Safeguards Order – scope of netting and set-off
2/17/2009 European Commission Commitment by 9 leading dealer firms to clear CDS in European CCP
2/13/2009

Russell Golden, FASB

ISDA Comments on Proposed Issue C22, Exception Related to Embedded Credit Derivatives
2/10/2009 CFTC (Commodity Futures Trading Commission) ISDA Comments on Proposed Rules Implementing the CFTC Reauthorization Act of 2008
2/8/2009 European Commission ISDA response to EC consultation on hedge funds
2/6/2009 Basel Committee on Banking Supervision Supervisory Guidance for Assessing Banks’ Financial Instrument Fair Value Practices
1/23/2009 FSA CP 08/17 Disclosure of Contracts for Difference ISDA responds jointly with LIBA to FSA Consultation on Disclosure of CfDs
1/20/2009 IASB (International Accounting Standards Board) ISDA's Comment Letter to IASB's Exposure Draft "Embedded Derivatives -- Amendments to IFRS 7 and IAS 39"

1/19/2009

Central Bank of the Republic of China (Taiwan)

* ISDA submission to Taiwan central bank regarding title transfer of dematerialised government bonds
1/15/2009 IASB (International Accounting Standards Board) ISDA's Comment letter on IASB's Exposure Draft on "Investments in Debt Instruments - Proposed Amendments to IRFS 7"
1/9/2009 HM Treasury ISDA response to consultation on UK Banking Bill Special Resolution Regime: safeguards for partial property transfers

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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.