ISDA No-Action Request to CFTC Regarding Swap Documentation Rules 23.502 and 23.504

ISDA submitted the attached no-action request to the CFTC on behalf of its members and other similarly situated persons with obligations under CFTC Swap Documentation Rules 23.502 (Portfolio Recognition) and 23.504 (Swap trading relationship documentation) asking that the compliance dates be pushed back to July 1, 2013. If approved, the relief would, among other things, allow market participants to delay entry into and compliance with "Protocol 2," the industry standard form being developed by ISDA (for which project Cadwalader serves as ISDA's counsel).