Cross-Border Application of Dodd-Frank

SIFMA and 12 other associations* provide comments to the Chairmen and Ranking Members for the U.S. Senate Banking, Housing and Urban Affairs, and Agriculture Committees sharing their serious concerns regarding the looming expiration (July 12, 2013) of an Exemptive Order issued by the Commodity Futures Trading Commission (CFTC), given previous market disruptions and the existing misalignment between the CFTC and both the Securities and Exchange Commission (SEC) and foreign jurisdictions.

Ultimately, failure to extend the existing Exemptive Order, or rushed efforts to finalize more permanent cross-border guidance before the July 12th deadline, would have avoidable consequences for U.S. competitiveness and business certainty, and could undermine sound and coordinated regulation that better protects our financial markets and the job creators they serve.

*SIFMA signed this joint-trade letter with: the American Bankers Association (ABA), the ABA Securities Association, the Business Roundtable, 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), the Partnership for New York City, The Clearing House (TCH), and the U.S. Chamber of Commerce.