On August 13, 2012, the International Swaps and Derivatives Association, Inc. (ISDA) released the August 2012 Dodd-Frank Protocol (Protocol) that addresses compliance with the final Dodd-Frank rules that will become effective shortly. Derivative counterparties, including end-users, will need to take proactive steps to adhere to the Protocol, including the submission of a Protocol adherence letter and questionnaire. End-users may find it increasingly difficult to enter into new derivative transactions or to modify existing derivative transactions with swap dealers unless they adhere to the Protocol before October 15, 2012. The Protocol also supplements the terms of existing derivative agreements (such as ISDA Master Agreements) which may require analyzing the terms of such existing agreements to understand the effect of Protocol adherence.