Comment Periods and Implementation of New Derivatives Regulations

SIFMA, the American Bankers Association (ABA), the ABA Securities Association, The Clearing House Association L.L.C. (TCH), the Financial Services Forum (FSF), the Financial Services Roundtable (FSR), 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 Managed Funds Association (MFA) provide comments to the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) on comments periods and implementation of new derivatives regulations.  The groups believe the new regulatory rules for derivatives provided in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) should be developed through a process that is deliberative, gives all parties reasonable opportunity to comment (and have their comments be given thoughtful consideration), and implements those rules in a manner that gives market participants sufficient time to do the work necessary to comply with new requirements being imposed on them.