SIFMA, the Financial Services Forum (FSF), the Futures Industry Association (FIA) and the International Swaps Dealers Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on a phase-in schedule for the requirements of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which addresses derivatives.  The groups recognize the enormous and delicate task of filling in the details of a revised derivatives regime through rulemaking.  Generally, Title VII requires the CFTC and the SEC to finalize these mandated rules by July 2011. As this deadline approaches, it has become increasingly clear to market participants and the Commissions, as well as legislators, that finalizing these rules will require more time than had been contemplated by the Dodd-Frank Act. The groups note that the Commissions have the flexibility to determine the effective dates for those finalized rules; and provide suggested timelines to best achieve the purpose and goals of the Dodd-Frank Act and the rulemaking process.