Reporting and Dissemination of Security-Based Swap Information

Comment Letter (SIFMA/ISDA)

SIFMA and ISDA submitted a joint comment letter to the SEC on Proposed Regulation SBSR, regarding the reporting and dissemination of security-based swap information. The letter (which is nearly 60 pages, including appendices) stresses the importance of black trade exemptions from certain of the real time public dissemination requirements of proposed Regulation SBSR, and includes a lengthy study of block trade reporting in OTC derivatives markets. In addition, the comment letter addresses, among other things, (1) consistency between the SEC rules and the rules of the CFTC and other non-US regulators; (2) trade allocations; (3) the use of unique identifiers; (4) error reporting; and (5) phased-in implementation of the new rules.

Please contact any of the following Cadwalader attorneys if you have any questions about this item:

Steven Lofchie; [email protected]

Jeffrey Robins; [email protected]

Date

January 18, 2011

Cross References (links may require a Cabinet subscription)

SEC Release 34-63346 (Proposed Reg. SBSR)

All comments received

http://sec.gov/comments/s7-34-10/s73410.shtml

Dodd-Frank §§ 763, 766