Transition Relief Under Title VII of the Dodd-Frank Act

SIFMA, the Future Industry Association (FIA), and the Institute of International Bankers (IIB) provide comments to the Commodity Futures Trading Commission (CFTC) requesting supplemental transition relief under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  To minimize the potential for very significant market disruption and uncertainty, the groups request that the Commission adopt the relief described in this letter, which is intended to supplement the other transition relief requests pending before the CFTC.