Clarification & Relief Under Sections 754 and 739 of the Dodd-Frank Act

SIFMA, the Futures Industry Association (FIA), the Institute of International Bankers (IIB), the International Swaps and Derivatives Association, Inc. (ISDA), the Investment Company Institute (ICI), and the U.S. Chamber of Commerce provide comments to the Commodity Futures Trading Commission (CFTC) requesting clarification and relief under Sections 754 and 739 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The groups specifically request that the CFTC utilize the full extent of  the CFTC exemptive authority, to ensure a coordinated implementation of both those provisions that are implemented directly through Commission rulemaking and those statutory provisions that depend upon (or “require”) related CFTC rulemaking. In addition, the groups request clarification of, and exemptive relief regarding, the treatment of swap transactions under the provisions of the Commodity Exchange Act (CEA) applicable to futures contracts.