ISDA Comment Letter On The Canadian Securities Administrators' (CSA) Consultation Paper 91-407 On Derivatives: Registration

The International Swaps and Derivatives Association, Inc. (ISDA) welcomes the opportunity to respond to the Consultation Paper published by the CSA on April 18, 2013 setting forth the CSA Derivatives Committee’s (Committee) proposal for the regulation of key derivatives market participants through the implementation of a registration regime in the Canadian over-the-counter (OTC) derivatives markets. We are pleased to share these comments with the CSA, in addition to our comment letters submitted to the CSA in connection with Consultation Paper 91-401 setting forth the CSA Derivatives Committee proposals regarding the regulation of OTC derivatives (the OTC Derivatives Consultation Paper) Consultation Paper 91-402 setting forth proposals for the reporting of OTC derivatives transactions and the operation of trade repositories, and Consultation Paper 91-406 on Derivatives: OTC Central Counterparty Clearing.