SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) regarding the implementation of certain of the business conduct standards applicable to swap/security-based swap dealers (collectively, Dealers) and major swap/security-based swap participants (collectively, MSPs) under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) in anticipation of proposed rulemakings by the Commissions.

SIFMA and ISDA urge the Commissions to consider the recommendations in connection with the proposal and adoption of business conduct standards for Dealers and MSPs including:

• Special Entities;
• Advising and Trading with Special Entities;
•  Disclosure Requirements;
• Daily Marks;
• Fair and Balanced Communication;
• Conflicts of Interest; and
• Trading Records.