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As a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Commodity Futures Trading Commission ("CFTC") has published rules to regulate the swaps marketplace. These rules require Fifth Third Financial Risk Management (FTFRM) to collect and maintain specific customer information. This information allows FTFRM, in its capacity as a swap dealer, to offer customers CFTC regulated financial risk management products.

On October 20, 2014 FTFRM, a division of Fifth Third Bank became a provisionally registered swap dealer with the CFTC and on November 4, 2014 an approved Member of National Futures Association ("NFA").


What Does This Mean for YOU?

The swaps industry has designed an online portal to electronically facilitate amending relationship documentation among trading counterparties (e.g. ISDA Protocol). Links to documentation which details how to use the ISDA Protocol are on the right margin.

If you have not already completed the swap trading relationship documentation with FTFRM please complete the following steps:


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Submit an adherence letter for ISDA August 2012 DF Protocol (Protocol 1)

Submit an adherence letter for ISDA March 2013 DF Protocol (Protocol 2)

You should receive an email notification for each adherence letter within three business days, which either confirms acceptance or requests changes or additional information required to complete the adherence process. Please keep a copy of the email confirmation(s) for your records, as confirmations will contain an adherence letter ID, which will be referenced later in the compliance process.


*If you receive an email notice stating that your adherence letter has been rejected, you will need to reach out to the appropriate contact in such email to discuss further.

Complete the ISDA Protocol compliance process on Markit.


  1. Sign up for the Markit Counterparty Management solutions product.
  2. Complete a Questionnaire for Protocol 1 and a Questionnaire for Protocol 2 (the Questionnaire for Protocol 2 will require your adherence letter ID).
  3. Select Fifth Third Bank as a counterparty to view your answers.