Extraterritorial Application of Title VII of the Dodd-Frank Act

SIFMA provides comments to the Commodity Futures Trading Commission (CFTC), the Securities and Exchange Commission (SEC), the Board of Governors of the Federal Reserve (Fed), the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Agency (FHFA), and the Farm Credit Administration (FCA) on the extraterritorial application of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that relate to the regulation of swap dealers.  The corresponding proposed regulations are the Registration of Swap Dealers and Major Swap Participants, RIN 3038-AC95; and the Further Definition of “Swap Dealer,” “Security-Based Swap Dealer,” “Major Swap Participant” and “Eligible Contract Participant,” RIN 3235-AK65. SIFMA offers its experience and expertise on the proposals and sets forth a proposed approach for how the U.S. regulators should exercise their jurisdiction over swap dealers and cross-border swaps activities.