ISDA provides comments regarding the recently released notice of proposed rules and advance notice of proposed rulemaking (“CFTC Margin Proposal”) concerning margin requirements for non-cleared 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”). Our analysis of the proposed rules and response to the proposed rulemaking addresses three critical themes: providing for implementation without excessive disruption; addressing systemic risk in an appropriate manner; and developing a workable cross-border framework.