SIFMA and the International Swap Dealers Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on business conduct standards for swap dealers and major swap participants with counterparties, RIN 3038-AD25. The proposed rules are intended to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The business conduct standards rules would govern the relationship between swap dealers and major swap participants and their counterparties, including “special entities” such as pension funds and state and local governments. The groups express concerns about various aspects of the CFTC’s proposal, including unintended adverse consequences for customers of swap dealers and instances where the CFTC has gone beyond the mandates of the underlying legislation.