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Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants

Issue

OTC Derivatives→

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed registration requirements for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs) as put forth in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), File No. S7-40-11.  While SIFMA generally supports the proposal, SIFMA makes several key recommendations including eliminating a “Senior Officer Certification” and allowing for limited designation and registration, including by trading unit, type of activity and type of counterparty.

 

PDF

Submitted To

SEC

Submitted By

SIFMA

Related Committee(s)

  • Swap Dealer Committee

Date

16

December

2011

Excerpt

Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-1090

Re: Proposed Rule on the Registration of Security-Based Swap Dealers and Major SecurityBased Swap Participants (File Number S7-40-11)

Dear Ms. Murphy:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the Securities and Exchange Commission’s (the “Commission’s”) proposed registration requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”) pursuant to Title VII of the Dodd-Frank Wall
Street Reform and Consumer Protection Act (“Title VII” of “Dodd-Frank”).2

SIFMA generally supports the Proposal and:

  • the Commission’s plan to publish a comprehensive Title VII implementation
    proposal;
  • the Commission’s (i) attempts to align SBSD and MSBSP registration
    requirements with the Commodity Futures Trading Commission’s (“CFTC’s”)
    proposed registration requirements and (ii) creation of a streamlined registration
    process for SBSDs and MSBSPs already registered with the Commission or the
    CFTC; and
  • the Commission’s plan to conduct a holistic review of Commission registration
    requirements.

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