Swaps Regulation - End-User Exception to Mandatory Clearing - Comment Letter - SIFMA - February 22, 2011

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Dodd-Frank Timeline, End-user Exception to Mandatory Clearing of Swaps, CFTC
Final Rule Issue Effective Date Compliance Date
July 19, 2012 September 17, 2012 April 10, 2013

End-User Exception to Mandatory Clearing of Swaps
February 22, 2011

Summary of points from the comment letter:

  • Congress, when enacting Dodd-Frank, "acknowledged that clearing may not be suitable for every transaction or every counterparty."
  • An exception to the clearing requirement may be critical to municipal market borrowers’ ability to access the interest rate swap market.
  • Borrowers should be eligible to elect to use the end-user exception to mandatory clearing.
  • SIFMA supports the Commissions' position that the question of whether an activity is commercial should not be determined solely by an entity’s organizational status as a for-profit company, a non-profit organization, or a governmental entity.

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