The ISDA 2021 SBS Top-Up Protocol (the “SBS Top-Up Protocol”) is part of ISDA’s Dodd-Frank Documentation Initiative aimed at assisting the industry in implementing and complying with the regulatory requirements imposed under Title VII of the Dodd–Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Specifically, the SBS Top-Up Protocol facilitates industry compliance with rulemakings promulgated by the U.S. Securities and Exchange Commission (“SEC”) related to Security-Based Swaps (“SBS”). For those parties who have adhered to either or both of ISDA’s August 2012 DF Protocol and March 2013 DF Protocol, this protocol allows the terms previously included by the parties for CFTC compliance to be “topped up” for SEC compliance.