SIFMA Comments to the U.S. Senate Agriculture Committee on Derivatives, Dodd-Frank and CFTC Reauthorization

SIFMA submitted a comment letter to the U.S. Senate Agriculture Committee as to the reauthorization of the Commodity Exchange Act (CEA), and thus the reauthorization of the CFTC. SIFMA encouraged the Ag Committee to consider the impact of how regulators, specifically the CFTC, are interpreting and proposing to implement the Dodd-Frank Act, particularly as to cross-border transactions and as to swap execution facilities, as to margin requirements on OTC swaps and as to the regulation of swaps between affiliates. The letter also expressed concern about a number of issues outside of the control of the CFTC, including the implementation of the swaps push-out rule and the adoption of Basel III.

View letter in full here (links to PDF).