The Over-the-Counter (OTC) Derivative Products Committee of the Securities Industry Association (SIA)* provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s Concept Release published May 7, 1998.  The Concept Release solicits comments as to whether the regulatory structure applicable to the OTC derivatives under the CFTC’s regulations should be modified in light of recent developments.

SIA opposes the proposal. In particular, SIA does not agree with the CFTC’s implicit premise that it has the statutory authority to impose a comprehensive regulatory regime for individually negotiated swaps and hybrids as contemplated by the Concept Release.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.