ISDA respectfully petitions the Commodity Futures Trading Commission (CFTC) under Commission regulation 13.2 to amend certain provisions in Parts 1, 37 and 43 of the Commission’s regulations. ISDA requests that the Commission amend certain provisions of the Commission’s regulations to more closely adhere to Congressional intent to establish a swaps trading platform regime that allows for flexible execution of swaps, to reduce undesirable regulatory outcomes that threaten the efficient functioning of markets, and to achieve cross-border harmonization of execution rules.