SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s proposed rulemaking regarding duties of swap dealers and major swap participants, RIN No. 3038-AC96.  The Commission proposed the framework to comply with provisions in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). SIFMA agrees with the CFTC that oversight begins with proper internal management of the activities of registrants. SIFMA offers its experience and expertise to align the proposed framework with current risk management capabilities and supervisory practices.