Swaps Definitions Regulation - Comment Letter - National Futures Association - February 22, 2011
|Proposal Date||Comment Deadline||Final Rule Issue|
|August 20, 2010||September 20, 2010||Late 2011|
|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."