The International Swaps and Derivatives Association, Inc. (“ISDA”) submitted a comment letter comments to the Canada Deposit Insurance Corporation (CDIC) with respect to the proposed CDIC Eligible Financial Contracts By-law set out in the Canada Gazette, Part I, Volume 155, Number 51, published December 18, 2021.   ISDA proposed phased timing of implementation of the stay provisions to allow for sufficient time to update contractual arrangements with counterparties to comply.