FIA Comments on CFTC’s Proposed Registration of Intermediaries
RIN 3038-AD50
May 10, 2011
FIA submitted a comment letter responding to the CFTC's notice of proposed rulemaking relating to the registration of intermediaries. The FIA letter expressed its support for a provision in the proposal that exempts foreign brokers who submit for clearing over-the-counter transactions that have been executed on a swap execution facility. FIA suggested this exemption be expanded to cover cleared bilateral transactions. Further, FIA urged the CFTC to confirm that associated persons of futures commission merchants would be exempt from being registered as an FCM if their activities are limited to submitting swaps transactions that were entered into between a swap dealer and its customers.
Cross References
Dodd-Frank Act, Title VII; 17 CFR Part 3