SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on the Commission’s proposed rules regarding the cross-border application of the registration thresholds and external business conduct standards applicable to swap dealers and major swap participants.

Among other comments, SIFMA AMG urged the Commission, among other derivatives regulators, to make substituted compliance more fully available, thereby promoting international comity and avoiding market disruption. SIFMA AMG also urged the Commission to reduce cross-border complexity and regulatory burdens by agreeing to defer to foreign jurisdictions and their regulations that achieve equivalent regulatory objectives and to do so on a more holistic basis.