Swap Dealers and Major Swap Participants Regulation - Comment Letter - Securities Industry and Financial Markets Association - January 18, 2011

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Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants
January 18, 2011

This comment letter addresses the following rules: Duties of swap dealers and major swap participants; SD-MSP Conflicts of Interest; CCO Designation; Reporting, Recordkeeping and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants.

Written on behalf of the Asset Management Group (AMG) of SIFMA, this comment letter argues that "the CFTC and SEC should consider different sets of regulations for swap dealers and MSPs, with MSP regulation focused primarily on default risk and swap dealer regulation focused on market-making, pricing and sales practices, as well as default risk." The letter also requests that the "CFTC formally extend the comment periods for the MSP Proposals and not take any action to finalize them until sufficient time has passed after finalization of the Definitions Proposals for the appropriate analyses to be undertaken and completed."

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