SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Task Force on Credit Default Swaps Regulation of the National Conference of Insurance Legislators (NCOIL) on proposed model legislation to regulate credit default swaps. The proposed model legislation to regulate credit default swaps (CDS) is under provisions patterned on New York’s current regulation of financial guaranty insurance, set forth in Article 69 of the New York Insurance Law. SIFMA understands the Task Force’s desire for detailed comments on the existing language of the proposed model legislation, our belief that the premise of regulating CDS under a financial guaranty insurance framework is flawed makes it difficult for us to provide useful comments in that form.