ISDA’s Comments on the CFTC’s NPR: Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements

International Swaps and Derivatives Association

February 28, 2011

ISDA has published a comment letter in response to the CFTC notice of proposed rulemaking in accordance with Section 731 of Title VII of the Dodd-Frank Act, which adds a new Section 4s(i), to the CEA, which in turn directs the CFTC to adopt

rules governing documentation standards for swap dealers and major swap participants. The Proposed Regulations would prescribe standards for the timely and accurate confirmation of swaps and would require the reconciliation and compression of swap portfolios.

Cross References

Proposed rule 4s(i); Section 731 of the Dodd-Frank Act