Policy Issues
Regulatory Comment Letters
Commodity Futures Trading Commission (CFTC)
- No-Action Relief, Aplication of Swap Trading Documentation Rules to FX Products, June 5, 2013
- Interpretive Request: Scope of IDI Exemption Over Loans from Operating Subsidiaries, April 30, 2013
- Interpretive Request: Scope of External Business Conduct Standards Over Exempt FX Transactions, April 3, 2013
- Data Reporting Implementation Date Extension Request, March 28, 2013
- Joint-Trade Comment, Proposed Amendment to CFTC Cross-Border Guidance, February 6, 2013
- Letter on Title VII Transition Relief, December 17, 2012
- Harmonization with CFTC JOBS Act Rules, October 17, 2012
- Concerns with Title VII October 12th Effectiveness Date, October 2, 2012
- Clearing Exception for Inter-Affiliate Swaps, September 20, 2012
- Treatment of Conditional Notional Amount in Mandatory Trading Determinations, September 6, 2012
- CFTC Cross-Border Guidance, August 27, 2012
- Exemptive Order on Cross-Border Application of Title VII Swaps Provisions, August 13, 2012
- Interim Final Rule--Exemption of Commodity Hedging from Definition of Swap Dealing, July 23, 2012
- Joint-Trade Comment Period Extension Request- Cross Border Interperative Release, July 15, 2012
- Joint-Trade Request for CFTC Roundtable on Data Reporting Issues, June 21, 2012
- SDR Indemnification Provisions Under CEA Section 21(d), June 6, 2012
- Comments on Identity Theft Red Flags, May 2, 2012
- Joint-Trade Submission on the Volcker Rule, April 16, 2011
- Determination of When a Swap is "Available to Trade", February 13, 2011
- Timing of Title VII Registration Provisions, February 2, 2011
- Swap Transaction Compliance & Implementation Schedule: Clearing & Trade Execution Requirements, November 4, 2011
- Swap Transaction Compliance & Implementation Schedule: Trading Documentation & Margining Requirements, November 4, 2011
- De Minimis & IDI Exemption Supplemental Letter , October 17, 2011
- Joint Trade Stable Value Contract Study Comment Letter, September 27, 2011
- Request for Comment Period Extension - Stable Value Contracts Study , September 16, 2011
- Joint Trade Letter on the Treatment of Inter-Affiliate Swaps, September 8, 2011
- Comments on Proposed Definition of Introducing Broker, August 19, 2011
- Definition of Swap and Security-Based Swap Under Title VII, July 22, 2011
- Margin and Capital Requirements for Covered Swap Entities, July 11, 2011
- Margin Requirements for Covered Swap Entities, July 12, 2011
- Volker Rule Preproposal Letter, June 14, 2011
- Automatically Effective Provisions Under Title VII and Application for Exemption Pending Final Rulemaking, June 10, 2011
- Reporting Requirements, Pre-Enactment and Transition Swaps , June 7, 2011
- Joint Trade Letter--Suggested Reproposal of Title VII Rules, May 26, 2011
- Documentation Requirements for Swap Dealers and Major Swap Participants, May 13, 2011
- Title VII Implementation Challenges , May 12, 2011
- Suggested Implementation Order for Dodd-Frank Title VII Rules, April 6, 2011
- Core Principles and Other Requirements for Swap Execution Facilities, March 8, 2011
- Swap Date Recordkeeping & Reporting Requirements, February 7, 2011
- Proposed Whistleblower Program, February 4, 2011
- Joint Trade Comments on Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges, January 11, 2011
- Process for Designating Swaps for Mandatory Clearing, January, 3, 2011
- CFTC Letter, Business Affiliate Marketing and Disposal of Consumer Information Rules, December 22, 2010
- CFTC Letter, Privacy of Consumer Financial Information; Conforming Amendments Under Dodd Frank Act, December 22, 2010
