Swaps Review Regulation - Comment Letter - Consortium of Foreign Banks - February 17, 2011

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Dodd-Frank Timeline, Process for Review of Swaps for Mandatory Clearing; Technical Amendments, SEC
Final Rule Issue Effective Date Compliance Date
June 28, 2012 August 13, 2012 December 10, 2012

Process for Submissions for Review of Security-Based Swaps for Mandatory Clearing and Notice Filing Requirements for Clearing Agencies
February 17, 2011

The letter is addressed to the CFTC, SEC and U.S. Federal Reserve Bank on behalf of 12 foreign banking institutions (Barclays Bank PLC, BNP Paribas S.A., Credit Suisse AG, Deutsche Bank AG, HSBC, Nomura Securities International Inc., Rabobank Nederland, Royal Bank of Canada, Royal Bank of Scotland Group PLC, Societe Generale, The Toronto-Dominion Bank and UBS AG).

The suggested modifications address the following questions, as stated in the comment letter:

  • Who is required to register as a swap dealer and with respect to what activities?
  • How does Title VII apply to limited registrants?
  • When will the Federal Reserve and the Commissions rely on home country requirements for entity-level regulation?
  • How do transaction-level rules apply to foreign banks whose registration is limited to swap dealing activities with U.S. persons?


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