SIFMA and the International Swaps Dealers Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) on the registration and regulation of security-based swap execution facilities (SB SEFs), File No. S7-06-11.  SIFMA supports the determination that a more flexible approach to rule-making will best serve to accomplish the goals of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act): migration of security-based (SB) swaps to regulated markets, greater transparency and increased competition. SIFMA generally supports the SEC’s approach to interpreting the definition of SB SEFs and devising rules for SB SEF regulation.  However, SIFMA raises concerns regarding:  (1) the organization and operation of SB SEFs; (2) trades exempt from mandatory execution on SB SEFs; (3) oversight and review of SB SEFs; and (4) other issues.

SIFMA Asset Management Group (AMG) also filed comments on the proposal on April 4, 2011.