The Regional Dealers Derivatives Committee of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) on the swap dealer and security-based swap dealer registration requirements and the end user clearing exemption for swaps and security-based swaps in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). SIFMA offers its observations and recommendations to improve areas of the rules including: the de minimis exemption; and the commercial risk exemption from mandatory clearing.