Requesting a Comment Deadline Extension for Certain Security-Based Swaps Rulemakings
Summary
SIFMA, The Financial Services Roundtable (FSR), the Futures Industry Association (FIA), the Institute of International Bankers, the International Swaps and Derivatives Association, Inc. (ISDA), and the Investment Company Institute (ICI) provide comments to the Securities and Exchange Commission (SEC) requesting an extension on the comment deadline on the reopening of comment periods for certain rulemaking releases and policy statement applicable to security-based swaps (SBS) proposed in accordance with the Securities Exchange Act of 1934 and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), RIN 3235-AK74, 3235-AK77, 3235-AK80, 3235-AK79, 3236-AK88, 3235-AK91, 3235-AK93, 3235-AL13, 3235-AL10, 3235-AL05, 3235-AL12.
The groups request that the SEC extend the deadline for comments on the Reopened Proposals until September 20, 2013, which is 30 days after the deadline for comments on the Cross-Border Proposal (i.e., 120 days after publication of the Cross-Border Proposal in the Federal Register). The groups believe this will afford them sufficient time to first analyze and prepare comments on the Cross-Border Proposal and then to consider the implications of the Cross-Border Proposal on the Reopened Proposals.
Excerpt
Financial Services Roundtable
Futures Industry Association
Institute of International Bankers
International Swaps and Derivatives Association
Investment Company Institute
Securities Industry and Financial Markets Association
May 21, 2013
Elizabeth M. Murphy
Secretary of the Commission
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Re: Request for Comment Deadline Extension on the Reopening of Comment Periods for Certain Rulemaking Releases and Policy Statement Applicable to SecurityBased Swaps Proposed Pursuant to the Securities Exchange Act of 1934 and the Dodd-Frank Wall Street Reform and Consumer Protection Act (RIN 3235-AK74, 3235-AK77, 3235-AK80, 3235-AK79, 3236-AK88, 3235-AK91, 3235-AK93, 3235-AL13, 3235-AL10, 3235-AL05, 3235-AL12)
Dear Ms. Murphy:
The undersigned associations1 appreciate the significant efforts of the Securities and Exchange Commission (the “Commission”) and its staff to take a holistic and thoughtful
approach to the treatment of cross-border security-based swap activities, as evidenced by the detailed and comprehensive proposed cross-border rules (the “Cross-Border
Proposal”)2 and the Commission’s actions to re-open comment periods for its previously proposed security-based swap rules and policy statement (the “Reopened Proposals”). 3 The associations recognize the Commission’s ongoing commitment to open dialogue with security-based swap market participants on these proposed rules, and its important efforts to coordinate with other regulators, both outside and inside the United States.
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1 Information about each of the trade associations that has signed this letter is contained in the Appendix.
2 Cross-Border Security-Based Swap Activities; Re-Proposal of Regulation SBSR and Certain Rules and Forms Relating to the Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants, RIN 3235-AL25 (initial release May 1, 2013), available at http://www.sec.gov/rules/proposed/2013/34-69490.pdf.
3 Reopening of Comment Periods for Certain Rulemaking Releases and Policy Statement Applicable to Security-Based Swaps Proposed Pursuant to the Securities Exchange Act of 1934 and the Dodd-Frank Wall Street Reform and Consumer Protection Act, RIN 3235-AK74, 3235-AK77, 3235-AK80, 3235-AK79, 3236-AK88, 3235-AK91, 3235-AK93, 3235-AL13, 3235-AL10, 3235-AL05, 3235-AL12 (initial release date May 1, 2013), available at http://www.sec.gov/rules/proposed/2013/34-69491.pdf.