Swap Dealers and Major Swap Participants Regulation - Comment Letter - FIA, ISDA, and SIFMA - January 18, 2011

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Conflicts of Interest for Swap Dealers, Major Swap Participants, Futures Commission Merchants, and Introducing Brokers
January 18, 2011

The associations provide the CFTC with recommendations regarding conflicts related to research, clearing, and customers. Among these recommendations are:

  • Regarding conflicts related to research, they suggest that the Commission "modify the Proposed Rules to permit research management to solicit the views of business trading and clearing unit personnel on analyst compensation and evaluation, provided that research management maintains exclusive authority over final decisions in these areas."
  • As an alternative to the proposed rules regarding clearing, the associations urge the commission instead to "adopt a more targeted rule to address the conduct the Dodd-Frank Act is seeking to address. This alternative rule prohibits the affiliated SD or MSP from obtaining information from the affiliated FCM clearing personnel concerning transactions conducted by FCM clients and requires the FCM clearing unit to have independent management to make the decisions regarding accepting new clearing clients."


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