Swap Trading Documentation Requirements for Swap Dealers

Published on:
April 8, 2011

SIFMA and the International Swap Dealers Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on swap trading relationship documentation requirements for swap dealers (SDs) and major swap participants (MSPs); and orderly liquidation termination provision in swap trading relationship documentation for swap dealers and major swap participants, RIN 3038-AC96.  The proposals would implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) regarding documentation and other requirements for SDs and MSPs.  SIFMA and ISDA support much the proposals.  The groups’ comments suggest ways in which the proposals can be clarified or refined to avoid undue costs and unintended consequences. But, the groups are deeply concerned that the CFTC’s proposal relating to valuation models and methods reflects fundamental misunderstandings of the processes by which swaps are negotiated and transacted, the nature of swap valuations and the causes of valuation disputes.

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.