SIFMA Provides comments to the Securities and Exchange Commission (SEC) on the external business conduct standards for security-based swap dealers and major SBS participants. Our recommendations are to harmonize the Proposed Rules with the CFTC EBC Rules. We believe consistency is important because most SBS Entities and their counterparties have already invested significant resources to comply and familiarize themselves with the CFTC EBC Rules. To the extent the two rule sets are consistent, it therefore will speed implementation, minimize counterparty confusion and lead to lower costs for SBS Entities and their counterparties.

See also:

Business Conduct Standards for Security-Based Swap Dealers and Major SecurityBased
Swap Participants