Swap Dealer Registration Requirements, Swap End User Clearing Exemption

The Regional Dealers Derivatives Committee of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) on the swap dealer and security-based swap dealer registration requirements and the end user clearing exemption for swaps and security-based swaps in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). SIFMA offers its observations and recommendations to improve areas of the rules including: the de minimis exemption; and the commercial risk exemption from mandatory clearing.