Proposed Rules for End-User Exception to Mandatory Clearing of Swaps

SIFMA’s Municipal Finance Products Committee provides comments to the Commodity Future Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on proposed rules for end-user exception to mandatory clearing of swaps, CFTC File RIN 3038-AD10; SEC File No. S7-43-10.  The proposed rules are intended to implement provisions of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) relating to the application of the exception to mandatory clearing of swaps and security-based swaps.  SIFMA believes that an exception to the clearing requirement may be critical to municipal market borrowers’ ability to access the interest rate swap market; and borrowers should be eligible to elect to use the end-user exception to mandatory clearing.