• Although the deadline to adhere to ISDA’s “Dodd-Frank Protocol I” has effectively been extended to May 1, 2013, T-H recommends that firms planning to adhere submit their protocol adherence letter and exchange questionnaires with dealer counterparties no later than March 31, 2013 to avoid processing delays that could occur as the deadline approaches.
  • Market participants should work with their counsel to ensure that they complete the necessary documentation well in advance of the compliance deadlines.
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