FIA submitted a comment letter to the CFTC regarding proposed rules on the cross-border application of the registration thresholds and external business conduct standards applicable to swap dealers and major swap participants. The letter supports and expands views shared by SIFMA and IIB and focuses on the scope of the proposed definition of a U.S. Person, an issue of particular importance to FIA. Specifically, FIA encourages the Commission to remove any regulatory uncertainty and, once again, make clear that the scope of the proposed definition of a US Person will not extend to those provisions of the CEA governing the activities of FCMs with respect to both (i) exchange-traded futures, whether executed on a designated contract market or a foreign board of trade, or (ii) cleared swaps.
The full letter is available in Resources on the right.
