The Sequencing of the Compliance Dates for Security-Based Swaps Final Rules
Summary
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s Statement of General Policy on the sequencing of the compliance dates for final rules applicable to security-based swaps under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). SIFMA believes that Title VII must be phased in as part of a comprehensive plan that recognizes and accounts for the significant serial dependencies and interdependencies that lie at the core of the transition process.
Excerpt
Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-1090
Re: Statement of General Policy on the Sequencing of the Compliance Dates for Final Rules Applicable to Security-Based Swaps
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”) Statement of General Policy (the “Policy Statement”) on the Sequencing of the Compliance Dates for Final Rules Applicable to Security-Based Swaps (“SBS”) Under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Title VII” of the “Dodd-Frank Act”).2
SIFMA believes that the Policy Statement reflects sound judgments regarding the order in which Title VII should be implemented. As we stated in a comment letter to the Commodity Futures Trading Commission (“CFTC”) on November 4, 2011 (the “November 4th Letter”),3 we believe that Title VII must be phased in as part of a comprehensive plan that recognizes and accounts for the significant serial dependencies and interdependencies that lie at the core of the transition process. In the November 4th Letter, we suggested an appropriate sequencing of Title VII requirements to meet these goals. We are pleased to see that the Policy Statement is largely in line with the sequencing we suggested.