Investment funds (or investment managers on their behalf) may now adhere to the ISDA March 2013 DF Protocol Agreement (“Protocol 2.0”). Protocol 2.0, as with the ISDA August 2012 DF Protocol (the “August Protocol”), is an efficient means for swap dealers to comply with certain new Commodity Futures Trading Commission (“CFTC”) rules applicable to bilaterally
ISDA August D-F Protocol Deadline Delayed Until May 1, 2013
The Dec. 31, 2012 deadline for adhering to the ISDA August 2012 Dodd-Frank Protocol published by the International Swaps and Derivatives Association (“ISDA”) has been delayed until May 1, 2013.
Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the Commodity Futures Trading Commission (“CFTC”) issued a number of business-conduct rules…
Update for Swap Counterparties: ISDA’s Dodd-Frank Protocol – Addition of Addendum I
ISDA has included an Addendum I (the “Addendum”) to the ISDA August 2012 Dodd-Frank Protocol Questionnaire (“Questionnaire”), which provides provisions addressing changes to certain “eligible contract participant” categories that will become effective on Dec. 31, 2012. The Addendum is relevant to any OTC Derivative Counterparties that are “commodity pools” and who (a) rely upon the…
Update for Swap Counterparties: New Web Portal Launched to Assign CFTC Interim Compliant Identifiers
The Depository Trust & Clearing Corporation (DTCC) and SWIFT have launched a Web portal to begin assigning CFTC Interim Compliant Identifiers (CICIs) as required by the CFTC’s Data and Recordkeeping Rule. All swap counterparties are required to be identified by a CICI. All swap counterparties currently adhering to the ISDA Dodd-Frank Protocol are required to…
Eurozone Crisis: ISDA Publishes the Illegality/Force Majeure Protocol
The International Swaps and Derivatives Association (“ISDA”) published the ISDA Illegality/Force Majeure Protocol (the “Protocol”) on 11 July 2012. The Protocol amends the 1992 version of the ISDA Master Agreement (“’92 ISDA”) to include the Illegality and Force Majeure provisions from the 2002 ISDA Master Agreement (“2002 ISDA”).
The Protocol is part of ISDA’s more…