International Swaps Regulation - Comment Letter - MarkitSERV - September 19, 2011

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CFTC and SEC Staff Roundtable on International Issues
September 19, 2011

Summary of recommendations from the comment letter:

  1. limit the amount of duplicative reporting and data fragmentation by "allowing counterparties to use Independent Verification Services (“IVS’”) for processing as well as reporting purposes", and "providing additional flexibility in their reporting requirements to reflect specific challenges in the international context";
  2. "permit counterparties to use international third party providers for their connectivity needs;"
  3. "explicitly state that international third party providers, whether or not they are United States-based, will not be required to comply with any DFA requirements for activities wholly outside of the United States;" and
  4. "clarify the extraterritorial reach of the DFA and the Commissions’ regulations in order to reduce uncertainty and avoid overlapping and inconsistent regulations with foreign regulators."


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