The International Swaps and Derivatives Association1 ("ISDA") appreciates this opportunity to provide comments to the Prudential Regulators2 (the "PRs") regarding the recently released - 2 - notice of proposed rulemaking and request for comments ("PR Margin Proposal")3 concerning margin and capital requirements for non-cleared swaps and non-cleared security-based swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").[...]