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ISDA General Disclosure D-F Update

ISDA has requested feedback regarding whether to update its General Disclosure Statement for Transactions. The 43 page General Disclosure forms the main body of a market-standard documentation suite intended to assist with risk disclosure requirements mandated by the CFTC’s External Business Conduct Rules (Rules 23.431, 23.450(g) and 23.605(e)). It is appended by a series of annexes for interest rate, foreign exchange, equity, credit, commodity and asset-backed securities classes. Although the disclosure statement is used by a large number of market participants, unsurprisingly ISDA go to some pains to inform members that they will accept no mea culpa from deficiencies in their suggested “non est mea culpa” disclosure template. Comments are to be submitted to Fred Quenzer ( by COB 24 April.

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