Swap Data Regulation - Comment Letter - Cleary Gottlieb Steen & Hamilton LLP - February 14, 2011

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Regulation SBSR - Reporting and Dissemination of Security-Based Swap Information
February 14, 2011

Cleary Gottlieb Steen & Hamilton LLP sent the following comment letter on behalf of Bank of America Merrill Lynch, BNP Paribas, Citi, Credit Agricole, Corporate and Investment Bank, Credit Suisse Securities (USA), Deutsche Bank AG, Morgan Stanley, Nomura Securities International Inc., PNC Bank, National Association, Societe Generale, UBS Securities LLC and Wells Fargo & Co.

The letter indicates that the SEC proposal will cause "confusion and speculation" with regard to block transactions. The firms also believe that the SEC's exclusion of equity total-return swaps (TRS) from the block transaction exception would "impair market liquidity significantly" and lend to inefficiencies within swaps markets.



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