Fanni Koszeg | Bloomberg LawCFTC Comment Letter, FIA/ISDA/SIFMA, (Nov. 4, 2011) The International Swaps and Derivatives Association (ISDA), the Futures Industry Association (FIA), and the Securities Industry and Financial Markets Association (SIFMA, and collectively, Associations) submitted a joint comment letter to the Commodity Futures Trading Commission (CFTC) on its proposed compliance and implementation schedules for clearing and trade execution requirements and documentation and margining requirements (together, Proposals). The Associations believe that in order to facilitate a successful transition plan that is "comprehensive, transparent, and minimally disruptive to the continued operation of swap markets," the CFTC should consider making certain changes to the Proposals. The Associations proposed a phase-in plan that sequences the requirements of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) in three stages and, within these stages, by type of market participant.
Stage One: Swap Data Repositories and Regulatory Reporting
Stage Two: Registration and Clearing
Stage Three: Swap Execution Facilities and Public Reporting
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