Business Conduct Standards for Swap Dealers and Major Swap Participants, Particularly Special Entities

Published on:
February 22, 2011
Submitted to:
CFTC
Submitted by:
Asset Management Group (AMG)

The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed business conduct standards for swap dealers and major swap participants, particularly relating to “Special Entities”, RIN 3038-AD25.  The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) defines “Special

Entities” to include government agencies, employee benefit plans under the Employee Retirement Income Security Act of 1974, governmental plans as defined in ERISA, endowments and municipalities.  AMG believes the proposal could result in unintended harm to Special Entities and would introduce unfair burdens and risks for investment advisers to Special Entities.

SIFMA AMG filed comments with the Securities and Exchange Commission (SEC) on August 29, 2011 in response to the SEC’s proposal regarding business conduct standards for security-based swap dealers and major security-based swap participants.

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.