ISDA’s Comment Letter on NPR Protection of Collateral of Counterparties to Uncleared Swaps
ISDA has submitted comments in response to the CFTC proposed rules to implement Section 724(c) of the Dodd-Frank Act. In general, ISDA's comments reflected that the rules should permit bilateral contract negotiation in place of formalistic rules where appropriate should strike a balance between the burden presented and the need to protect the interests of counterparties who are, by definition, deemed to be able to protect their own interests.
Date
February 1, 2011
Cross References
724(c) of the Dodd-Frank Act