Swaps Definitions Regulation - Comment Letter - National Futures Association - February 22, 2011

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Dodd-Frank Timeline, Swaps Definitions - ANPR
Proposal Date Comment Deadline Final Rule Issue
August 20, 2010 September 20, 2010 Late 2011
Dodd-Frank Timeline, Further Defining “Swap Dealer,” “Major Swap Participant” and “Eligible Contract Participant”
Final Rule Issue Effective Date Compliance Date
May 23, 2012 July 23/Dec. 31, 2012 October 12, 2012

Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant"
February 22, 2011

NFA explains that because the Proposed Rule 1.3(qqq) defines MSP as a person that is not an SD, this prohibits a person from becoming registered as both an SD and MSP. They argue that "theoretically one entity could be an SD with respect to one type of swap and an MSP with respect to a different swap category... Therefore, NFA requests that the Commission clarify whether and in what cases a person may be registered as both an SD and MSP."


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