Key Definitions in the Derivatives Title of the Dodd-Frank Act

The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on key definitions in the derivatives title (Title VII) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) and joint regulation by the Commissions of “mixed swaps,” File No. S7-16-10.  The AMG believes the terms “swap dealers,” “security-based swap dealers,” “major swap participants” and “major security-based swap participants” should be further defined by regulation.