De Minimis Exception from Certain Swap Participant Definitions

SIFMA’s Regional Dealers Derivatives Committee provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on proposed rules regarding the de minimis exception from the definition of “swap dealer” and “security-based swap dealer,” in addition the Committee provides recommendations to change the definition of “eligible contract participant,” RIN 3235-AK65, File No. S7-39-10.  The Committee believes that the de minimis exception proposed by the CFTC and the SEC is unnecessarily narrow, will discourage smaller dealers from competing in the market and will limit the availability of efficient and cost-effective intermediation services to small- and medium-sized organizations.