Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants

Published on:
December 16, 2011
Submitted to:
SEC
Submitted by:
SIFMA
File Number:
S7-40-11

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed registration requirements for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) as put forth in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), File No. S7-40-11.  While SIFMA generally supports the proposal, SIFMA makes several key recommendations including eliminating a “Senior Officer Certification” and allowing for limited designation and registration, including by trading unit, type of activity and type of counterparty.

Excerpt

Ms. Elizabeth M. Murphy

Secretary

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549-1090

Re: Proposed Rule on the Registration of Security-Based Swap Dealers and Major SecurityBased Swap Participants (File Number S7-40-11)

Dear Ms. Murphy:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the Securities and Exchange Commission’s (the “Commission’s”) proposed registration requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”) pursuant to Title VII of the Dodd-Frank Wall

Street Reform and Consumer Protection Act (“Title VII” of “Dodd-Frank”).2

SIFMA generally supports the Proposal and:

  • the Commission’s plan to publish a comprehensive Title VII implementation

    proposal;

  • the Commission’s (i) attempts to align SBSD and MSBSP registration

    requirements with the Commodity Futures Trading Commission’s (“CFTC’s”)

    proposed registration requirements and (ii) creation of a streamlined registration

    process for SBSDs and MSBSPs already registered with the Commission or the

    CFTC; and

  • the Commission’s plan to conduct a holistic review of Commission registration

    requirements.

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