Letters

Security-Based Swap CCO/Supervision Standards

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the internal business conduct standards for security-based swap dealers and major security-based swap participants. SIFMA’s recommended modifications are generally intended to harmonize the Proposed Rules with the FINRA Supervision Rule, the FINRA CCO Rule and the CFTC CCO Rule. Harmonization of the rules will allow SBS Entities to leverage existing processes and speed implementation. It will also enhance the ability of SBS Entities to identify and remediate non-compliance issues by permitting personnel to focus on the substance of issues rather than allocating resources to comply with the formalities of multiple overlapping but slightly differing rules.

 

PDF

Submitted To

SEC

Submitted By

SIFMA

Committee

Municipal Securities Division

Date

23

September

2015