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