SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide supplemental comments to the Commodity Futures Trading Commission (CFTC) on several proposals relating to business conduct and chief compliance officer requirements:

• Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties, RIN 3038-AD25;
• Regulations Establishing and Governing the Duties of Swap Dealers and Major Swap Participants, RIN 3038-AC96;
• Implementation of Conflicts of Interest Policies and Procedures by Swap Dealers and Major Swap Participants, RIN 3038-AC96; and
• Designation of a Chief Compliance Officer; Required Compliance Policies; and Annual Report of a Futures Commission Merchant, Swap Dealer, or Major Swap Participant, RIN 3038-AC96.

The groups urge the CFTC in the strongest possible terms to work closely with the Securities and Exchange Commission (SEC) to harmonize the Commissions’ rules relating to the external and internal business conduct standards, including the chief compliance officer requirements, applicable to swap dealers, major swap participants, security-based swap dealers and major security-based swap participants under the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).