ISDA wishes to commend the CFTC for showing leadership in consideration of the financial resource requirements on DCOs and systemically important DCOs (SIDCOs). These financial resource requirements are an important contributor to financial stability and we would encourage CFTC (the Commission) to set clearly robust standards building on the earlier (and continuing) work of the Committee on Payment and Settlement Systems (CPSS) and the International Organization of Securities Commissions (IOSCO). 

The public policy rationale for the Dodd-Frank Act is to reduce risk, increase transparency and promote financial markets by, inter alia, imposing financial resource requirements on DCOs and SIDCOs to enable them to perform their central risk management function, as mandated by the Dodd-Frank Act. ISDA believes that public policy objective is best served by the Commission imposing prudent and appropriately conservative financial resources requirements on DCOs and SIDCOs.

Full letter