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Determination of Major Swap Participant

Issue

OTC Derivatives→

Summary

The Asset Management Group (AMG) of SIFMA provides additional comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on determining whether an entity is a “major swap participant” or “major security based swap participant” (collectively MSP), File No. S7-16-10.  The AMG supplements the comments from its letter dated September 20, 2010 and forwards additional comments regarding issues raised during a meeting with staffs of the respective Commissions and representatives of AMG.

PDF

Submitted To

CFTC, SEC

Submitted By

SIFMA AMG

Date

24

November

2010

Excerpt

Mr. David A. Stawick
Secretary
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington DC 20581

Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-1090

Re: Definitions / File Number S7-16-10

Dear Mr. Stawick and Ms. Murphy:

The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to supplement our letter to the Commodity Futures Trading Commission (the “CFTC”) and the Securities and Exchange Commission (the “SEC” and, together with the CFTC, the “Commissions”) dated September 20, 2010 (the “AMG Letter”) and provide the Commissions with additional comments regarding issues raised during a November 1, 2010 meeting held among members of the respective staffs of the Commissions and representatives of the AMG.

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