SIFMA provides comments to the Commodity Futures Trading Commision (CFTC) on the applicability of commodity pool regulation to insurance-linked securities (ILS).  SIFMA requests the CFTC provide interpretive guidance and other appropriate relief with the result that ILS transactions will not be regulated as commodity pools under the Commodity Exchange Act (as amended, the CEA) by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act), including those ILS transactions that do not satisfy the non-exclusive safe harbor for certain insurance transactions not being a swap.