SIFMA, the American Bankers Association (ABA), The Financial Services Roundtable (FSR), and The Clearing House (TCH) submit comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s notice of proposed rulemaking implementing new Section 13 of the Bank Holding Company Act of 1956 (Volcker Rule), a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The groups add to their collective comments to multiple federal regulators on the proprietary provisions of the proposed Volcker Rule and the provisions relating to private funds restrictions.

The groups focus their comments on issues that are particularly relevant to the CFTC and respond to specific questions asked by the CFTC. The groups’ observations and recommendations cover multiple areas of the CFTC’s proposal including cost-benefit analysis, permitted activities related to the swaps dealing markets, and the inconsistency of proposal’s negative presumptions with the Dodd-Frank Act.