On December 18, 2012, the CFTC introduced interim final rules for swap contracts and key swap participants and extended the compliance date from January 1, 2013 to May 1, 2013 for the various external behaviour provisions under the ISDA August D-F protocol. In addition, the provisional final rules extend the deadlines for compliance with the Commission`s portfolio coordination and swap trade relations documentation until 1 July 2013 (the documentary changes required by these rules will be included in a second ISDA protocol to be published shortly). This relief was brought with the hope and understanding that the industry will continue to rely on it. In this context, we encourage market participants to comply with the ISDA August D-F protocol and to make questionnaires available to counterparties in a timely manner before the compliance deadline of May 1, 2013. Contracting parties can enter into the DF Terms Agreement and choose the provisions of the DF supplement they wish to include by participating in the August 2012 ISDA protocol. A party wishing to use the DF protocol to conclude the DF conditions can do so in the same way that it uses the DF protocol to complement its existing written agreements, i.e. by exchanging questionnaires with another participant in the protocol who wishes to conclude a DF agreement. The protocol does not apply to documents relating to centrally matched derivatives transactions, nor to agreements in which the parties expressly provide that the terms of the protocol do not apply. 2.Q What is a “protocol” and how does the August 2012 ISDA-DF protocol differ from previous ISDA protocols? In order to comply with the rules adopted by the CFTC pursuant to Dodd-Frank Title VII, swap counterparties must obtain certain information from counterparties and verify whether counterparties are considered “eligible parties” (which requires the counterparty to identify the specific number of the applicable authorized participant definition when the swap trader relies on counterparty insurance).