Conflict of Interest Policies & Procedures for FCMs, IBs & SDs & MSPs

SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provides comments to the Commodity Futures Trading Commission (CFTC) on implementation of conflicts of interest policies and procedures by futures commission merchants (FCMs) and introducing brokers (IBs); and swaps dealers (SDs), and major swap participants (MSPs), RIN 3038-AC96. The Commission’s proposed rules relate to sections 731 and 732 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The groups offer their observations and recommendations for: 1) the Commission’s proposed Rule 1.71 of the Commodity Exchange Act (CEA) regarding conflicts of interest polices and procedures for futures commission merchants (FCMs) and introducing brokers (IBs); and 2) the Commission’s proposed Rule 23.605 of the CEA regarding conflicts of interest policies and procedures for swaps dealers (SDs) and major swap participants (MSPs).