The Sequencing of the Compliance Dates for Security-Based Swaps Final Rules

Published on:
August 13, 2012
Submitted to:
SEC
Submitted by:
SIFMA

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.

Continue Reading >

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

Get the latest trends, stats, and research on financial markets and securities.