FIA, SIFMA and FSR jointly filed this comment letter on the application of Commission regulations to swaps between non-U.S. swap dealers and non-U.S. counterparties involving personnel or agents of the non-U.S. swap dealers located in the United States. The letter encourages the Commission to abandon personnel-based elements to the cross-border application of its swaps rules and provides recommendations to the issues presented in the staff advisory.
