SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s proposed compliance and implementation schedules for swap clearing, trade execution, documentation and margin, RIN 3038-AD60, RIN 3038-AC96, RIN 3038-AC97.  The groups believe that a successful transition requires a plan that is comprehensive, transparent and minimally disruptive to the continued operation of the swap markets.  In addition, the groups note that a phased-in plan would be the best approach, and proposes a plan that sequences requirements of Title VII of the Dodd Frank Act in three stages.