Earlier this week ISDA published the ISDA August 2012 DF Protocol (the “DF Protocol”), which is now open for adherence.
- What It Does: By adhering to the DF Protocol, parties will amend and supplement swap trading documentation to facilitate compliance with a number of final Commodity Futures Trading Commission (“CFTC”) rules, including the CFTC’s business conduct standards for swap dealers (the “Business Conduct Standards”).
- Why: The October 15, 2012 compliance deadline for the Business Conduct Standards is rapidly approaching. Therefore market participants that intend to trade swaps on and after this deadline must address these and other requirements in a timely manner in order to comply with the relevant rules. ISDA expects that the DF Protocol will reduce the likelihood of “disruptions to trading” that could accompany a slower, bilateral amendment process.