SIFMA, the American Bankers Association, the American Benefits Council, the Committee on Investment of Employee Benefit Assets, The ERISA Industry Committee, the Financial Executives International’s Committee on Corporate Treasury, the Financial Services Roundtable, the Insured Retirement Institute, the National Association of Insurance and Financial Advisors, and the National Association of Manufacturers provide comments to the Commodity Futures Trading Commission (CFTC) on business conduct standards for swap dealers and major swap participants with counterparties, RIN 3038-AD25.  The groups believe that preserving and strengthening the private retirement system is vital and helps ensure the retirement security of millions of Americans. In that regard, the groups express a very deep level of concern with respect to the business conduct standards for swap dealers and major swap participants recently proposed by the CFTC.