SIFMA’s Municipal Finance Products Committee provides comments to the Commodity Future Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on proposed rules for end-user exception to mandatory clearing of swaps, CFTC File RIN 3038-AD10; SEC File No. S7-43-10.  The proposed rules are intended to implement provisions of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) relating to the application of the exception to mandatory clearing of swaps and security-based swaps.  SIFMA believes that an exception to the clearing requirement may be critical to municipal market borrowers’ ability to access the interest rate swap market; and borrowers should be eligible to elect to use the end-user exception to mandatory clearing.