Professional Associations - Comments on ET Guidance

CFA Institute: CFA Institute suggested that the Commission accommodate the interim registration of non-U.S. firms as Swap Dealers and Major Swap Participants as they wait for the implementation of comparable regulation in their home markets. In addition, the Institute believes that the Commission should avoid shortcuts in the due diligence needed to implement the Proposal in order to meet their deadlines.

U.S. Chamber of Commerce: Commerce discussed setting an appropriate scope for the Dodd-Frank extraterritorial application, which is crucial for achieving effective cross-border swaps regulation. Specifically, the Commerce argued that an overly broad extraterritorial application of new derivatives regulations could create competitive disadvantages for U.S. firms. It could also invite other jurisdictions to attempt to extend their regulatory reach into the U.S., creating transatlantic and global duplication that ultimately harms the competitiveness of American businesses and runs counter to other policy initiatives designed to jumpstart the economy and job creation.

Additional Letters: Available here.

Cross-Reference(s): Dodd-Frank Act Title VII.

View Release in full here (links externally to CFTC website).