On Nov. 29, FIA submitted a letter to the Securities and Exchange Commission and the Commodity Futures Trading Commission proposing several areas where the agencies could coordinate and harmonize their regulatory programs for cleared derivatives. FIA focused in particular on simplifying rules that apply to firms that are dually registered as futures commission merchants with the CFTC and as broker-dealers with the SEC. These areas include record-keeping, reporting, margin rules, and oversight of products subject to both agencies' authority. FIA also proposed codifying certain exemptions for security-based swaps.