The International Swaps and Derivatives Association, Inc. (“ISDA”) appreciates the opportunity to provide the Board of Governors of the Federal Reserve System (the “Board”) with comments and recommendations regarding the notice of proposed rulemaking (the “Proposed Rule”) promulgated by the Board regarding restrictions on qualified financial contracts (“QFCs”) of systemically important U.S. banking organizations and the U.S. operations of systemically important foreign banking organizations (together, “Covered Entities”).