MFA and AIMA Submit Comments on SEC's Proposed Cross-Border Rules for Security-Based Swaps

The Managed Funds Association ("MFA") and the Alternative Investment Management Association ("AIMA") submitted joint comments to the SEC in response to the SEC's proposed rules on cross-border security-based swap activities. The letter begins by complimenting the SEC on the approach that it is taking with regard to swaps rulemaking - e.g., adopting its rules as a whole, rather than in part - and for working with other regulators. The letter urges harmonization of regulation between the various regulators, including the CFTC and the SEC. More substantively, the MFA and the AIMA argue generally for materially broader recognition of substituted compliance with respect to transaction level swap obligations.

See: MFA and AIMA Comment Letter; MFA Blog Release.See also: IIB Files Comments on CFTC Cross-Border Exemptive Order (with Lofchie Comment) (August 16, 2013); Industry Groups Submit Critical Comments on CFTC Cross-Border Guidance (with Lofchie Comment) (August 13, 2013); SEC Proposal on Cross-Border Security-Based Swaps (with Commissioners' Comments) (with Lofchie Comment) (May 1, 2013).