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Comments on Concept Release: Definitions Contained in Title VII of Dodd-Frank Wall Street Reform and Consumer Protection Act

[Release No. 34-62717; File No. S7-16-10]

See also: Comments on Proposed Rule: Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant"; File No. S7-39-10 and
Comments on Dodd-Frank Title VII, Security-Based Swap Dealers and Major Security-Based Swap Participants


Submitted Comments

(Click here for meetings with SEC officials)
Comments have been received from individuals and entities using the following Letter Type A: 1566
Sep. 12, 2011 Christopher A. Klem, Ropes & Gray LLP
Sep. 8, 2011 ABA Securities Association, American Council of Life Insurers, Financial Services Roundtable, Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association
May 31, 2011 Futures Industry Association, The Financial Services Roundtable, Institute of International Bankers, Insured Retirement Institute, International Swaps and Derivatives Association, Securities Industry and Financial Markets Association, and U.S. Chamber of Commerce
May 4, 2011 Financial Services Forum, Futures Industry Association, International Swaps and Derivatives Association, and Securities Industry and Financial Markets Association
Apr. 14, 2011 "Swap Dealers and Major Swap Participants Should Not be Treated as Identical Twins" submitted by Blackrock
Apr. 5, 2011 John F. Gandolfo, Acting Vice President & Treasurer, The World Bank
Mar. 24, 2011 Richard H. Baker, President & Chief Executive Officer, Managed Funds Association
Mar. 18, 2011 Gunter Pleines, Head of Banking Department and Diego Devos, General Counsel, Bank for International Settlements
Mar. 1, 2011 Elliot Ganz, General Counsel, The Loan Syndications & Trading Association
Feb. 23, 2011 Clare Dawson, Managing Director, Loan Market Association
Feb. 22, 2011 National Corn Growers Association and Natural Gas Supply Association
Feb. 22, 2011 Lee Ming Chua, General Counsel, Government of Singapore Investment Corporation Pte Ltd, Singapore
Feb. 18, 2011 Stacy C. Kymes, Executive Vice President, BOK Financial
Feb. 18, 2011 CFTC Phase-in Implementation Discussion
Feb. 3, 2011 Gerald Donini, Barclays Capital Inc.
Jan. 25, 2011 R. Bram Smith, Executive Direcor, The Loan Syndications and Trading Association, New York, New York
Dec. 14, 2010 James Michener, General Counsel, Assured Guaranty Ltd.
Dec. 5, 2010 Chris Barnard, Germany
Nov. 24, 2010 Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Nov. 10, 2010 Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy and Advocacy, Securities Industry and Financial Markets Association
Nov. 9, 2010 Comment Letter from the National Association of Insurance Commissioners regarding a September 29, 2010 meeting with Securities and Exchange Commission and the Commodity Futures Trading Commission
Nov. 5, 2010 Americans for Financial Reform
Nov. 4, 2010 Dexter Senft, Managing Director, Morgan Stanley
Nov. 2, 2010 James P. Hoffa, General President, and C. Thomas Keegel, General Secretary-Treasurer, The International Brotherhood of Teamsters
Nov. 1, 2010 James Hill, Managing Director, Morgan Stanley
Oct. 27, 2010 Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy and Advocacy, SIFMA
Sep. 24, 2010 Patrick J. Nugent, Executive Director, Texas Pipeline Association
Sep. 24, 2010 Richard A. Miller, Esq., Vice President and Corporate Counsel, Financial Management Law, The Prudential Insurance Company of America
Sep. 24, 2010 Andrew Baker, Chief Executive Officer, The Alternative Investment Management Association
Sep. 24, 2010 Convexity Capital Management LP
Sep. 23, 2010 Stuart J. Kaswell, Executive Vice President, Managing Director & General Counsel, Managed Funds Association
Sep. 21, 2010 Dan Shackelford and Jonathan D. Siegel, T. Rowe Price Associates, Inc.
Sep. 21, 2010 Edward J. Rosen, Cleary Gottlieb Steen & Hamilton LLP
Sep. 20, 2010 Thaddeus Huettemann, Jeffrey C. Fort, and Jeremy D. Weinstein; Environmental Markets Association
Sep. 20, 2010 Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Sep. 20, 2010 Coalition for Derivatives End-Users
Sep. 20, 2010 Timothy W. Cameron, Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Sep. 20, 2010 Jennifer J. Kalb, Associate General Counsel, Metropolitan Life Insurance Company, Morristown, New Jersey
Sep. 20, 2010 Ernest C. Goodrich, Jr. and Marcelo Riffaud, Deutsche Bank AG
Sep. 20, 2010 Richard M. Whiting, Financial Services Roundtable
Sep. 20, 2010 Kenneth A. Kopelman, Bingham McCutchen LLP, on behalf of Union Bank, N.A., Regions Bank and Fifth Third Bancorp
Sep. 20, 2010 Eric Dennison, Stephanie Miller, and Bill Hellinghausen, EDF Trading North America, LLC
Sep. 20, 2010 Edward W. Gallagher, President, Dairy Risk Management Services, Dairy Farmers of America, Inc.
Sep. 20, 2010 Lisa M. Ledbetter, Vice President and Deputy General Counsel, Freddie Mac
Sep. 20, 2010 Richard F. McMahon, Jr., Executive Director, Edison Electric Institute
Sep. 20, 2010 American Benefits Council and the Committee on the Investment of Employee Benefit Assets
Sep. 20, 2010 Anne Simpson, Senior Portfolio Manager, Global Equity, California Public Employees' Retirement System
Sep. 20, 2010 Anthony M. Mansfield and Jonathan H. Flynn, McDermott Will & Emery LLP, on behalf of the Hess Corporation
Sep. 20, 2010 Karrie McMillan, General Counsel, Investment Company Institute
Sep. 20, 2010 Gus Sauter, Chief Investment Officer, Vanguard
Sep. 20, 2010 Joanne T. Medero, Managing Director, BlackRock
Sep. 20, 2010 William J. Brodsky, Chairman and Chief Executive Officer, Chicago Board Options Exchange, Incorporated
Sep. 20, 2010 Steve Martinie, Assistant General Counsel and Assistant Secretary, Northwestern Mutual Life Insurance Company
Sep. 20, 2010 White & Case LLP
Sep. 20, 2010 Jane L. Cline, President, and Therese M. Vaughan, Ph.D., Chief Executive Officer, National Association of Insurance Commissioners
Sep. 20, 2010 Stephen H. McElhennon, Vice President & Deputy General Counsel, Fannie Mae
Sep. 20, 2010 Kathleen L. Barrón, Esq., Vice President, Federal Regulatory Affairs and Policy, Noel Trask, Esq., Lead Counsel, Exelon Power Team, Exelon Corporation, and David M. Perlman, Bracewell & Giuliani LLP
Sep. 20, 2010 David Carroll, Senior Counsel, American Express Company
Sep. 20, 2010 Patrick Kelly, Policy Advisor, American Petroleum Institute
Sep. 20, 2010 David M. Perlman, on behalf of the Coalition of Physical Energy Companies
Sep. 20, 2010 Jay Brown, Chief Executive Officer, MBIA Inc.
Sep. 20, 2010 John M. Damgard, President, Futures Industry Association
Sep. 20, 2010 H. Steven Walton, Frederic Dorwart, Lawyers, on behalf of Bank of Oklahoma National Association
Sep. 20, 2010 Not-For-Profit Energy End User Coalition
Sep. 20, 2010 Jane Hamblen, State of Wisconsin Investment Board
Sep. 20, 2010 Richard Ostrander, Managing Director and Counsel, Morgan Stanley
Sep. 20, 2010 American Seniors Housing Association, Building Owners and Managers Association International, International Council of Shopping Centers, NAIOP, the Commercial Real Estate Development Association, National Apartment Association, National Association of Real Estate Investment Trusts, National Multi Housing Council, and The Real Estate Roundtable
Sep. 20, 2010 Robert J. Duke, Director of Underwriting/Assistant Counsel, The Surety & Fidelity Association of America
Sep. 20, 2010 Thomas W. Jasper, Chief Executive Officer, Primus Guaranty Ltd. and Gene Park, Chief Executive Officer, Quadrant Structured Investment Advisers, LLC
Sep. 20, 2010 Stephen Linehan, Executive Vice President and Treasurer, Capital One Financial Corporation
Sep. 20, 2010 Thomas Book, Member of the Executive Board, and Vassilis Vergotis, Executive Vice President, Eurex and Eurex Clearing AG
Sep. 20, 2010 Carolyn Walsh, Vice President and Senior Counsel Center for Securities, Trust & Investments, American Bankers Association
Sep. 20, 2010 J. Stephen Zielezienski, Senior Vice President & General Counsel, American Insurance Association
Sep. 20, 2010 Robert Pickel, Executive Vice Chairman, International Swaps and Derivatives Association, Inc.
Sep. 20, 2010 Lee Ming Chua, General Counsel, Government of Singapore Investment Corporation
Sep. 20, 2010 The Swaps & Derivatives Market Association
Sep. 20, 2010 Franklin W. Nutter, President, Reinsurance Association of America
Sep. 20, 2010 Andrew Baker, Chief Executive Officer, The Alternative Investment Management Association
Sep. 17, 2010 William E. Balson, Director, OTC Online, LLC and Dr. Gordon C. Rausser, Robert Gordon Sproul Distinguished Professor, University of California, Berkeley
Sep. 17, 2010 James M. Olsen, Senior Director Accounting and Investment Policy, Property Casualty Insurers Association of America
Sep. 17, 2010 Leo Pylypec, Managing Director, FTN Financial Capital Markets
Sep. 15, 2010 Joel G. Newman, President & CEO, American Feed Industry Association
Sep. 13, 2010 James M. Michener, General Counsel, Assured Guaranty Corp.
Sep. 9, 2010 Keith M. Sappenfield, II, Director, US Regulatory Affairs, Midstream, Marketing and Fundamentals, Encana Marketing (USA) Inc.
Sep. 5, 2010 Andrew Reyburn, Michigan
Sep. 2, 2010 Christopher Klem, Ropes & Gray LLP, Boston, MA
Jul. 30, 2010 Charles W. Wilcoxson
Jul. 28, 2010 Robin McLeish, Virginia Beach, Virginia
Feb. 3, 2010 Coalition for Derivatives End-Users

Meetings with SEC Officials

(Click here for submitted comments from the public)
Aug. 10, 2012 Memorandum from the Division of Trading and Markets regarding an August 6, 2012, meeting with representatives from the Association of Financial Guaranty Insurers
Jun. 15, 2011 Memorandum from the Division of Trading and Markets regarding a June 15, 2011 meeting with representatives of the Investment Company Institute
May 20, 2011 Memorandum from the Division of Trading and Markets regarding a May 20, 2011, meeting with representatives from Morgan Stanley
May 20, 2011 Memorandum from the Division of Trading and Markets regarding a May 15, 2011, meeting with representatives from Siemens Corporation
May 13, 2011 Memorandum from the Division of Trading and Markets regarding a May 13, 2011, meeting with a representative from Kalorama Partners, LLC
May 13, 2011 Memorandum from the Division of Trading and Markets regarding a May 12, 2011, meeting with representatives from Barclays Capital
May 13, 2011 Memorandum from the Division of Trading and Markets regarding an April 27, 2011, meeting with representatives from the Securities Industry and Financial Markets Association (SIFMA)
May 11, 2011 Memorandum from the Division of Trading and Markets regarding a May 11, 2011, telephonic meeting with Robert Colby of Davis Polk & Wardwell LLP
May 11, 2011 Memorandum from the Division of Trading and Markets regarding a May 9, 2011, telephonic meeting with representatives the Capital Steering Committee of the Securities Industry and Financial Markets Association (SIFMA)
May 4, 2011 Memorandum from the Division of Trading and Markets regarding a May 4, 2011, meeting with representatives of the Institute of International Bankers (IIB)
Mar. 30, 2011 Memorandum from the Division of Trading and Markets regarding a March 30, 2011, meeting with representatives of Nomura Securities International, Inc.
Mar. 28, 2011 Memorandum from the Division of Trading and Markets regarding a March 28, 2011 telephonic meeting with representatives of Cleary Gottlieb Steen & Hamilton LLP
Mar. 28, 2011 Memorandum from the Division of Trading and Markets regarding a March 28, 2011 telephonic meeting with representatives of International Swaps and Derivatives Association, Inc.
Mar. 28, 2011 Memorandum from the Division of Trading and Markets regarding a March 24, 2011 telephonic meeting with Edward Rosen
Mar. 25, 2011 Memorandum from the Division of Trading and Markets regarding a March 25, 2011, meeting with representatives of Goldman Sachs
Mar. 23, 2011 Memorandum from the Division of Trading and Markets regarding a March 18, 2011 telephonic meeting with representatives of Markit
Mar. 21, 2011 Memorandum from the Division of Trading and Markets regarding a March 21, 2011 telephonic meeting with representatives of International Swaps and Derivatives Association, Inc.
Mar. 9, 2010 Memorandum from the Division of Trading and Markets regarding a March 9, 2011 meeting with a representative of the Goldman Sachs Group, Inc.
Mar. 9, 2011 Memorandum from the Division of Trading and Markets regarding a March 9, 2011, meeting with representatives from and members of the Managed Funds Association (MFA)
Mar. 3, 2011 Memorandum from the Division of Trading and Markets regarding a March 3, 2011, meeting with representatives of the Institute of International Bankers (IIB)
Mar. 1, 2011 Memorandum from the Division of Trading and Markets regarding a March 1, 2011, meeting with representatives of Nomura Holding America Inc. and Nomura Securities International, Inc
Feb. 23, 2011 Memorandum from the Division of Trading and Markets regarding a February 23, 2011 meeting with representatives of the Property Casualty Insurers Association of America
Feb. 22, 2011 Memorandum from the Division of Trading and Markets regarding a telephonic meeting with representatives of the Capital Steering Committee of the Securities Industry and Financial Markets Association (SIFMA)
Feb. 17, 2011 Memorandum from the Division of Trading and Markets regarding a February 17, 2011 meeting with representatives of the Bank for International Settlements
Feb. 14, 2011 Memorandum from the Division of Trading and Markets regarding a February 14, 2011 meeting with representatives of Weil, Gotshal & Manges LLP
Feb. 10, 2011 Memorandum from the Division of Trading and Markets regarding a January 27, 2011, meeting of the OTC Derivatives Supervisors Group (ODSG) with major participants in the OTC derivatives market
Feb. 10, 2011 Memorandum from the Division of Trading and Markets regarding a January 27, 2011, meeting of the OTC Derivatives Supervisors Group (ODSG) with major participants in the OTC derivatives market
Feb. 4, 2011 Memorandum from the Division of Trading and Markets regarding a February 4, 2011, telephonic meeting with Ed Rosen of Cleary Gottlieb Steen & Hamilton LLP
Jan. 31, 2011 Memorandum from the Office of Commissioner Walter regarding a January 31, 2011, meeting with representatives of Nomura Holding America Inc.
Nov. 17, 2010 Memorandum from the Division of Trading and Markets regarding a November 17, 2010 meeting with representatives of Property Casualty Association of America
Nov. 16, 2010 Memorandum regarding an October 14, 2010 meeting with representatives of Depository Trust Clearing Corporation
Nov. 12, 2010 Memorandum from the Office of Commissioner Walter regarding a November 12, 2010 meeting with representatives of the International Swaps and Derivatives Association
Nov. 12, 2010 Memorandum from the Division of Trading and Markets regarding a November 12, 2010 meeting with representatives of MetLife
Nov. 12, 2010 Memorandum from the Division of Trading and Markets regarding a November 10, 2010 meeting with representatives of ERISA-Regulated Pension Plans
Nov. 8, 2010 Memorandum from the Division of Trading and Markets regarding a November 8, 2010 meeting with representatives of the American Council of Life Insurers
Nov. 4, 2010 Memorandum from the Division of Trading and Markets regarding a November 4, 2010 meeting with representatives of the Credit Derivatives Product Companies
Nov. 4, 2010 Memorandum from the Division of Trading and Markets regarding a November 4, 2010 meeting with representatives of the Association of Institutional Investors
Oct. 28, 2010 Memorandum from the Division of Trading and Markets re: Meeting with the Capital Steering Committee of the Securities Industry and Financial Markets Association
Oct. 28, 2010 Memorandum from the Division of Trading and Markets re: Phone Conference with Representatives of the Depository Trust and Clearing Corporation
Oct. 27, 2010 Memorandum from the Division of Trading and Markets regarding an October 27, 2010 phone conference with representatives of Chatham Financial
Oct. 14, 2010 Memorandum from the Office of Commissioner Troy A. Paredes regarding a October 14, 2010 meeting with representatives of UBS
Oct. 13, 2010 Memorandum from the Division of Trading and Markets regarding an October 13, 2010 meeting with representatives of various Buy-Side Firms
Oct. 8, 2010 Memorandum from the Division of Trading and Markets regarding an October 8, 2010 meeting with representatives of Bank of America
Oct. 8, 2010 Memorandum from the Office of the Chairman regarding an October 6, 2010, meeting with representatives of the Financial Services Forum
Oct. 8, 2010 Memorandum from the Office of the Chairman regarding an October 1, 2010, meeting with representatives of the Financial Services Roundtable
Oct. 6, 2010 Memorandum from the Office of Commissioner Walter regarding an October 6, 2010 meeting with representatives of PIMCO
Oct. 5, 2010 Memorandum from the Office of the Chairman regarding an October 5, 2010 meeting with representatives of JP Morgan
Oct. 5, 2010 Memorandum from the Division of Trading and Markets regarding an October 4, 2010 meeting with representatives of the Association of Institutional Investors
Oct. 4, 2010 Memorandum from the Division of Trading and Markets regarding an October 4, 2010 meeting with Morgan Stanley
Sep. 29, 2010 Memorandum from the Division of Trading and Markets regarding a September 29, 2010 meeting with representatives of the National Association of Insurance Commissioners
Sep. 28, 2010 Memorandum from the Division of Trading and Markets regarding a September 28, 2010, meeting with representatives of the Coalition for Derivatives End Users
Sep. 23, 2010 Memorandum from the Division of Trading and Markets regarding a September 23, 2010, meeting with representatives of Javelin Capital Markets, LLC
Sep. 23, 2010 Memorandum from the Division of Trading and Markets regarding a September 23, 2010, meeting with representatives of the Pan-Canadian Investors Committee for Third-Party Structured Asset-Backed Commercial Paper
Sep. 23, 2010 Memorandum from the Division of Trading and Markets regarding a September 21, 2010 meeting with the Financial Services Roundtable
Sep. 22, 2010 Memorandum from the Division of Trading and Markets re: U.S. Chamber of Commerce, Center for Capital Markets Competitiveness event on "Over the Counter (OTC) Derivatives Reform: Preparing for a Changing Marketplace."
Sep. 22, 2010 Memorandum from the Division of Trading and Markets regarding an September 22, 2010 meeting with representatives of Assured Guaranty
Sep. 20, 2010 Memorandum from the Division of Trading and Markets regarding a September 20, 2010 meeting with representatives of Goldman Sachs
Sep. 20, 2010 Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting with the CFTC and representatives from certain pension plans
Sep. 20, 2010 Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting with certain industry representatives
Sep. 17, 2010 Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting (p.m.) with representatives of Morgan Stanley
Sep. 17, 2010 Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting (a.m.) with representatives of Morgan Stanley
Sep. 15, 2010 Memorandum from the Division of Trading and Markets regarding an October 13, 2010 meeting with representatives of the Not-For-Profit Energy End User Coalition
Sep. 15, 2010 Memorandum from the Office of Commissioner Paredes regarding a September 8, 2010, meeting with representatives of Credit Suisse
Sep. 15, 2010 Memorandum from the Office of Commissioner Troy A. Paredes regarding an August 31, 2010 meeting with representatives of the Managed Funds Association
Sep. 10, 2010 Memorandum from the Division of Trading and Markets regarding a September 9, 2010 meeting with representatives of the Alternative Investment Management Association (AIMA)
Sep. 9, 2010 Memorandum from the Office of Commissioner Aguilar regarding a September 8, 2010 meeting with representatives from the Alternative Investment Management Association
Sep. 9, 2010 Memorandum from the Office of Commissioner Walter regarding a September 8, 2010 meeting with representatives from the Alternative Investment Management Association
Sep. 7, 2010 Memorandum from the Division of Trading and Markets regarding a September 2, 2010 meeting with representatives of Assured Guaranty
Sep. 2, 2010 Memorandum from the Division of Trading and Markets regarding an August 25, 2010 meeting with representatives of MarkitSERV
Sep. 1, 2010 Memorandum from the Division of Trading and Markets regarding a September 1, 2010 meeting with representatives from the Conference of State Bank Supervisors ("CSBS"), the National Association of Insurance Commissioners ("NAIC"), and the North American Securities Administrators Association ("NASAA")"
Sep. 1, 2010 Memorandum from the Division of Trading and Markets regarding a September 1, 2010 teleconference with representatives of Goldman, Sachs & Co. and Goldman Sachs Execution & Clearing LLC
Sep. 1, 2010 Memorandum from the Office of Commissioner Walter regarding an August 31, 2010 meeting with representatives of the Managed Funds Association
Aug. 31, 2010 Memorandum from the Division of Trading and Markets regarding an August 31, 2010 meeting with representatives of the Managed Funds Association
Aug. 30, 2010 Memorandum from the Division of Trading and Markets regarding an August 27, 2010 meeting with representatives of Americans for Financial Reform, et al.
Aug. 26, 2010 Memorandum from the Division of Trading and Markets regarding an August 26, 2010 meeting with representatives of the International Swaps and Derivatives Association (ISDA)
Aug. 25, 2010 Memorandum from the Division of Trading and Markets regarding an August 25, 2010 meeting with representatives of the Securities Industry and Financial Markets Association (SIFMA), et al.
Aug. 25, 2010 Memorandum from the Office of International Affairs regarding an August 25, 2010 meeting with a representative of the Institute of International Finance
Aug. 24, 2010 Memorandum from the Office of International Affairs regarding an August 16, 2010 meeting with representatives of the Government of Singapore Investment Corporation
Aug. 24, 2010 Memorandum from the Division of Trading and Markets regarding an August 24, 2010 meeting with representatives of Trumarx Data Partners
Aug. 24, 2010 Memorandum from the Division of Trading and Markets regarding an August 23, 2010 meeting with representatives of the National Association of College and University Business Officers (NACUBO)
Aug. 23, 2010 Memorandum from the Division of Trading and Markets regarding an August 23, 2010 meeting with representatives of D.E. Shaw
Aug. 17, 2010 Memorandum from the Division of Trading and Markets regarding an August 12, 2010 meeting with representatives of the dealer industry
Aug. 13, 2010 Memorandum from the Office of Commissioner Troy A. Paredes regarding an August 13, 2010 meeting with representatives from The Cypress Group and Koch Companies Public Sector, LLC
Aug. 10, 2010 Memorandum from the Division of Trading and Markets regarding an August 9, 2010 meeting with representatives of Americans for Financial Reform, et al.
Aug. 3, 2010 Memorandum from the Division of Trading and Markets regarding an August 3, 2010 meeting with representatives of the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association

 

http://www.sec.gov/comments/s7-16-10/s71610.shtml

Modified: 10/16/2014