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SIFMA and the American Securitization Forum (ASF) submitted the comments to the CFTC requesting relief to address "legacy" structured finance transactions. The groups stated that there are factors that distinguish these financings from those done on a prospective basis, which would therefore lessen the CFTC's regulatory interests and justify regulatory relief on a broader basis. A draft exemptive order was submitted for purposes of discussion (included in the letter). The structures to which the relief would apply are as below: "Legacy Entity" means an entity, regardless of its legal form

SIFMA and the Financial Services Institute ("FSI") provided joint legal analysis to the Virginia State Corporation Commission ("Virginia SCC") in support of the view that the point-of-sale disclosure requirements in Rule 21 VAC 5-20-280 A(32) of the Virginia Register of Regulations are preempted by, among other things, Section 103 of the National Securities Markets Improvement Act of 1996 ("Broker-Dealer Exemptions from State Law"), which preempts state regulation of broker-dealer capital, margin, books and records, bonding and reports. See: SIFMA and FSI Comment Letter.