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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"

[Release No. 34-63452; File No. S7-39-10]

See also: Comments on Definitions Contained in Title VII of Dodd-Frank Wall Street Reform and Consumer Protection Act 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)
Mar. 14, 2013 Thomas D'Ambrosio, Chair, The Committee on Futures and Derivatives, New York City Bar Association
May 17, 2012 Anne-Marie Leroy, Senior Vice Presidentand Group General Counsel, World Bank, and Rachel Robbins, Vice President and General Counsel, International Finance Corporation
Apr. 16, 2012 Michel Barnier
Apr. 6, 2012 Dennis M. Kelleher, President & CEO; Stephen W. Hall, Securities Specialist; and David Frenk, Research Director, Better Markets, Inc.
Mar. 15, 2012 Memorandum from the Division of Risk, Strategy, and Financial Innovation regarding Information regarding activities and positions of participants in the single-name credit default swap market
Feb. 17, 2012 National Corn Growers Association and Natural Gas Supply Association
Feb. 14, 2012 Diana L. Preston, Vice President and Senior Counsel, Center for Securities, Trust & Investments, American Bankers Association
Jan. 19, 2012 James Kemp, Managing Director, Global Foreign Exchange Division, and Stuart J. Kaswell, Executive Vice President & Managing Director, Managed Funds Association
Jan. 10, 2012 James Kemp, Managing Director, Global Foreign Exchange Division, and Stuart J. Kaswell, Executive Vice President & Managing Director, Managed Funds Association
Nov. 29, 2011 Capital One Financial Corporation, Fifth Third Bancorp and Regions Financial Corporation
Nov. 23, 2011 Brian Knapp, Policy Advisor, American Petroleum Institute
Nov. 3, 2011 Diana L. Preston, Vice President and Senior Counsel Center for Securities, Trust & Investments, American Bankers Association
Oct. 17, 2011 Richard M. Whiting, Executive Director and General Counsel, Financial Services Roundtable
Sep. 15, 2011 Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Aug. 15, 2011 Barry Taylor-Brill, Managing Counsel, Law Department, Wells Fargo & Company, Charlotte, North Carolina
Jul. 8, 2011 Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Jun. 15, 2011 Christopher J. Ailman, Chief Investment Officer, California State Teachers' Retirement System
Jun. 15, 2011 Fifth Third Bank
Jun. 12, 2011 Steven M. Felsenthal, General Counsel and Chief Compliance Officer, Millburn Ridgefield Corporation, Greenwich, Connecticut
Jun. 12, 2011 Scott Warren
Jun. 10, 2011 Bill C. Messick
Jun. 3, 2011 Mark D. Young, Skadden, Arps, Slate, Meagher & Flom LLP
June 3, 2011 Jennifer Canel, Senior Counsel, Wells Fargo & Company
May 31, 2011 Andrew W. Sherman, Esq. General Counsel, Rabobank, N.A., Rabo AgriFinance, Inc., and Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A
May 11, 2011 Branch Banking and Trust Company, East West Bank, Fifth Third Bank, The PrivateBank and Trust Company, Regions Bank, SunTrust Bank, U.S. Bank National Association, and Wells Fargo Bank, N.A.
May 6, 2011 The Bank of Tokyo-Mitsubishi UFJ, Ltd., Mizuho Corporate Bank, Ltd. and Sumitomo Mitsui Banking Corporation
Mar. 25, 2011 Thomas Happel, Executive Director Banking Supervision, Die Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Mar. 24, 2011 Richard H. Baker, President & Chief Executive Officer, Managed Funds Association
Mar. 4, 2011 Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, U.S. Senate Committee on Homeland Security and Government Affairs
Feb. 28, 2011 Christopher J. Ailman, Chief Investment Officer, California State Teachers' Retirement System
Feb. 24, 2011 Gary DeWaal, Senior Managing Director and Newedge Group General Counsel, Newedge USA, LLC
Feb. 22, 2011 Timothy P. Selby, Chair, Committee on Futures and Derivatives Regulation, New York City Bar Association
Feb. 22, 2011 Winthrop N. Brown, Milbank, Tweed, Hadley & McCloy LLP
Feb. 22, 2011 Lee Ming Chua, General Counsel, Government of Singapore Investment Corporation Pte Ltd
Feb. 22, 2011 Natural Gas Supply Association and National Corn Growers Association, Washington, District of Columbia
Feb. 22, 2011 Daniel F. C. Crowley, Partner, K&L Gates, on behalf of the Church Alliance
Feb. 22, 2011 Michael Slocum, Executive Vice President, Banking, Capital One Financial Corporation
Feb. 22, 2011 White & Case LLP
Feb. 22, 2011 Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Feb. 22, 2011 Frank Iacono, Partner, Riverside Risk Advisors LLC
Feb. 22, 2011 Americans for Financial Reform
Feb. 22, 2011 Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Feb. 22, 2011 Jennifer J. Kalb, Associate General Counsel, MetLife
Feb. 22, 2011 Dennis M. Kelleher, President & CEO; Stephen W. Hall, Securities Specialist; and Wallace C. Turbeville, Derivatives Specialist, Better Markets, Inc.
Feb. 22, 2011 Karrie McMillan, General Counsel, Investment Company Institute and Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association
Feb. 22, 2011 American Benefits Council and Committee on Investment of Employee Benefit Assets
Feb. 22, 2011 Karrie McMillan, General Counsel, Investment Company Institute
Feb. 22, 2011 Rita M. Molesworth, Willkie Farr & Gallagher LLP
Feb. 22, 2011 Joanne Medero, BlackRock, Inc.
Feb. 22, 2011 Warren Davis, Counsel, Sutherland Asbill & Brennan LLP
Feb. 22, 2011 Lisa M. Ledbetter, Vice President and Deputy General Counsel, Legislative & Regulatory Affairs, Freddie Mac
Feb. 22, 2011 Sullivan and Cromwell LLP
Feb. 22, 2011 Gerald W. McEntee, Intenational President, American Federation of State, County and Municipal Employees
Feb. 22, 2011 Richard M. Whiting, Executive Director and General Counsel, Financial Services Roundtable
Feb. 22, 2011 Walter L. Hawkins, Jr., Senior Vice President - Finance, Peabody Energy Corporation
Feb. 22, 2011 Gus Sauter, Managing Director and Chief Investment Officer, Vanguard and John Hollyer, Principal and Head of Risk Management and Strategy Analysis, Vanguard
Feb. 22, 2011 Robert Pickel, Executive Vice Chairman, International Swaps and Derivatives Association, Inc.
Feb. 22, 2011 Michael S. Edwards, Senior Assistant General Counsel, Credit Union National Association
Feb. 22, 2011 Stuart J. Kaswell, Executive Vice President & Managing Director, General Counsel, Managed Funds Association
Feb. 22, 2011 J. Stephen (“Stef”) Zielezienski, Senior Vice President & General Counsel, American Insurance Association
Feb. 22, 2011 David Carroll, Senior Counsel, American Express Company
Feb. 22, 2011 Diana L. Preston, Deputy General Counsel, ABA Securities Association, Vice President and Senior Counsel, Center for Securities, Trust & Investments, American Bankers Association
Feb. 22, 2011 White & Case LLP
Feb. 22, 2011 Mark Scanlan, Vice President, Agriculture & Rural Policy, Independent Community Bankers of America
Feb. 22, 2011 Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy Advocacy, Securities Industry and Financial Markets Association, Washington, District of Columbia
Feb. 22, 2011 R. Glenn Hubbard, Co-Chair, John L. Thornton Co-Chair, and Hal S. Scott, Director, Committee on Capital Markets Regulation
Feb. 22, 2011 Mark J. Ugoretz, President & CEO, The ERISA Industry Committee
Feb. 22, 2011 Joseph W. Brown, CEO, MBIA Inc., Armonk, New York
Feb. 22, 2011 Joel S. Telpner, Partner, Jones Day, on behalf of Canadian Master Asset Vehicles, New York, New York
Feb. 22, 2011 Scott Goebel, Senior Vice President and General Counsel, Fidelity Management & Research Company
Feb. 22, 2011 Mike Nicholas, Chief Executive Officer, Bond Dealers of America
Feb. 22, 2011 Christopher A. Klem, Ropes & Gray LLP
Feb. 22, 2011 Tessema Tefferi, Associate Director of Regulatory Affairs, National Association of Federal Credit Unions
Feb. 22, 2011 Paul Architzel, WilmerHale LLP, on behalf of ONEOK, Inc.
Feb. 22, 2011 Mary Richardson, Director of Regulatory and Tax Department, the Alternative Investment Management Association (AIMA), London, United Kingdom
Feb. 22, 2011 William H. Sirakos, Senior Executive Vice President, The Frost National Bank, San Antonio, Texas
Feb. 22, 2011 Wang Jianxi, Executive Vice President & CRO, China Investment Corporation
Feb. 22, 2011 Jack A. Hartings, The Peoples Bank Co., Coldwater, Ohio
Feb. 22, 2011 Guus Warringa, Chief Counsel, APG Algemene Pensioen Groep NV, Amsterdam, Netherlands
Feb. 18, 2011 Yngve Slyngstad, Chief Executive Officer, and Marius Nygaard Haug, Global Head of Legal, Norges Bank Investment Management
Feb. 18, 2011 Stacy C. Kymes, Executive Vice President, BOK Financial
Feb. 18, 2011 Bruce E. Stern, Association of Financial Guaranty Insurers
Feb. 18, 2011 Laura J. Schisgall, Managing Director and Senior Counsel, Societe Generale
Feb. 17, 2011 Barclays Bank PLC, BNP Paribas S.A., Credit Suisse AG, Deutsche Bank AG, HSBC, Nomura Securities International, Inc., Rabobank Nederland, Royal Bank of Canada, The Royal Bank of Scotland Group plc, Société Générale, The Toronto-Dominion Bank and UBS AG
Feb. 17, 2011 Patrick B Gonzalez, Chief Executive Officer, Athilon Structured Investment Advisors LLC
Feb. 17, 2011 Richard A. Miller, Esq, Vice President Corporate Counsel, Prudential Financial (copyrighted material redacted)
Feb. 15, 2011 Russell Goldsmith, Chairman, Midsize Bank Coalition Of America, Los Angeles, California
Feb. 14, 2011 Tom Deutsch, Executive Director, American Securitization Forum
Feb. 11, 2011 Christian Noyer, Chairman, Autorité de Contrôle Prudentiel and Jean-Pierre Jouyet, Chairman, Autorité des Marchés Financiers, Paris, France
Feb. 3, 2011 Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy and Advocacy, SIFMA
Jan. 31, 2011 Stanley A. Lybarger, President & Chief Executive Officer, BOK Financial Corporation
Jan. 31, 2011 Stanley A. Lybarger, President & CEO, BOK Financial Corporation
Jan. 31, 2011 Steven Kahn, Invicta Advisors LLC; Richard Claiden, Primus Guaranty Ltd.; and Eugene Park, Quadrant Structured Investment Advisers LLC
Jan. 12, 2011 Paul J. Pantano, Jr., McDermott Will & Emery, on behalf of the Agricultural Commodity Swaps Working Group
Jan. 11, 2011 Davis Polk & Wardwell LLP, on behalf of Barclays Bank PLC, BNP Paribas S.A., Deutsche Bank AG, Royal Bank of Canada, The Royal Bank of Scotland Group plc, Société Générale and UBS AG
Jan. 10, 2011 Sarah Miller, Chief Executive Officer, Institute of International Bankers, New York, New York
Jan. 7, 2011 Chris Barnard, Germany
Dec. 23, 2010 Edward Prosser, Vice President, Agricultural Trading, The Gavilon Group, LLC
Dec. 16, 2010 Representative Spencer Bachus, Ranking Member, House Committee on Financial Services and Representative Frank Lucas, Ranking Member, House Committee on Agriculture

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
Apr. 18, 2012 Memorandum from the Office of Commissioner Walter regarding a March 15, 2012 meeting with representatives of Better Markets
Apr. 4, 2012 Memorandum from the Office of Commissioner Aguilar regarding an April 3, 2012 meeting with representatives of Americans for Financial Reform, AFL-CIO, Consumer Federation of America, and Public Citizen
Mar. 26, 2012 Memorandum from the Division of Trading and Markets regarding a March 26, 2012, call with representatives from the Managed Funds Association
Mar. 22, 2012 Memorandum from the Division of Trading and Markets regarding a March 22, 2012, call with a representative from Better Markets
Mar. 7, 2012 Memorandum from the Division of Trading and Markets regarding a March 7, 2012, meeting with representatives from Better Markets
Mar. 5, 2012 Memorandum from the Office of Commissioner Paredes regarding a February 29, 2012, telephone conference call with representatives of Goldman Sachs
Feb. 29, 2012 Memorandum from the Office of Commissioner Luis A. Aguilar regarding a February 29, 2012, meeting with representatives of Better Markets
Feb. 16, 2012 Memorandum from the Division of Trading and Markets regarding a February 16, 2012, call with staff from the Senate Committee on Banking, Housing, and Urban Affairs
Feb. 2, 2012 Memorandum from the Office of Commissioner Luis A. Aguilar regarding a February 1, 2012, meeting with representatives of SIFMA
Jan. 20, 2012 Memorandum from the Division of Trading and Markets regarding a January 30, 2012, call with representatives from the National Association of Insurance Commissioners ("NAIC")
Dec. 12, 2011 Memorandum from the Office of Commissioner Paredes regarding a December 8, 2011, meeting with representatives of Bank of America; Barclays Capital; BNP Paribas; Credit Agricole; Deutsche Bank; Goldman Sachs; Morgan Stanley; Nomura; RBC; Societe Generale; Wells Fargo; HSBC; Davis, Polk; SIFMA and Citibank
Dec. 7, 2011 Memorandum from the Office of Commissioner Walter regarding a Meeting with Representatives of the Securities Industry and Financial Markets Association
Nov. 16, 2011 Memorandum from the Division of Trading and Markets regarding a November 16, 2011, call with representatives from DRW Trading, Chicago Trading Company, Infinium Capital Management, and Delta Strategy Group
Oct. 19, 2011 Memorandum from the Division of Trading and Markets regarding an October 19, 2011, meeting with representatives from the Financial Services Roundtable
Aug. 12, 2011 Memorandum from the Division of Trading and Markets regarding an August 12, 2011, call with representatives from Ambac Credit Products LLC
Aug. 8, 2011 Memorandum from the Division of Trading and Markets regarding an August 8, 2011, telephonic meeting with representatives from The Depository Trust & Clearing Corporation
Jul. 6, 2011 Memorandum from the Division of Trading and Markets regarding a July 6, 2011, telephonic meeting with representatives from The Depository Trust & Clearing Corporation (DTCC)
Jun. 29, 2011 Memorandum from the Office of Commissioner Paredes regarding a June 29, 2011, meeting with representatives of Bank of America
May 19, 2011 Memorandum from the Division of Trading and Markets regarding a May 17, 2011, meeting with representatives from the Securities Industry and Financial Markets Association (SIFMA)
Apr. 28, 2011 Memorandum from the Division of Trading and Markets regarding an April 28, 2011, meeting with representatives of the the Working Group of Commercial Energy Firms
Apr. 21, 2011 Memorandum from the Office of the Chairman regarding an April 21, 2011, meeting with representatives of the International Swaps and Derivatives Association, Inc.
Apr. 20, 2011 Memorandum from the Office of Commissioner Aguilar regarding an April 20, 2011, meeting with representatives of the International Swaps and Derivatives Association, Inc.
Apr. 20, 2011 Memorandum from the Office of Commissioner Walter regarding an April 20, 2011, meeting with representatives the International Swaps and Derivatives Association, Inc.
Apr. 18, 2011 Memorandum from the Division of Trading and Markets regarding an April 18, 2011, telephonic meeting with representatives from Athilon Structured Investment Advisors LLC
Apr. 15, 2011 Memorandum from the Division of Trading and Markets regarding a Meeting with Representatives of the California State Teachers' Retirement System
Apr. 13, 2011 Memorandum from the Division of Trading and Markets regarding an April 13, 2011, meeting with representatives from electric utilities
Apr. 7, 2011 Memorandum from the Division of Trading and Markets regarding an April 7, 2011, telephonic meeting with representatives from Credit Derivative Product Companies (CDPC)
Apr. 7, 2011 Memorandum from the Division of Trading and Markets regarding an April 7, 2011, meeting with representatives of the Coalition for Derivatives End-Users
Apr. 5, 2011 Memorandum from the Office of Commissioner Aguilar regarding an April 1, 2011 meeting with representatives of the CFA Institute
Apr. 4, 2011 Memorandum from the Office of Commissioner Paredes regarding an April 1, 2011 meeting with representatives of the Institute of Institutional Bankers, Davis Polk & Wardwell LLP, and Cleary Gottlieb Steen & Hamilton LLP
Apr. 1, 2011 Memorandum from the Office of Commissioner Aguilar regarding an April 1, 2011 meeting with representatives of the Institute of Institutional Bankers, Davis Polk & Wardwell LLP, and Cleary Gottlieb Steen & Hamilton LLP
Mar. 31, 2011 Memorandum from the Division of Trading and Markets regarding a March 31, 2011 telephonic meeting with representatives of the Commodity Futures Trading Commission and the International Swaps and Derivatives Association, Inc.
Mar. 23, 2011 Memorandum from the Division of Trading and Markets regarding a March 23, 2011, meeting with representatives from the Credit Union National Association and Chevron Federal Credit Union
Mar. 22, 2011 Memorandum from the Division of Trading and Markets regarding a March 22, 2011, meeting with representatives of the Asset Management Group of the Securities Industry Financial Markets Association
Mar. 21, 2011 Memorandum from the Division of Trading and Markets regarding a March 21, 2011, telephonic meeting with representatives of Northland Energy Trading LLC
Mar. 18, 2011 Memorandum from the Division of Trading and Markets regarding a March 18, 2011 Meeting with Representatives of Chatham Financial
Mar. 17, 2011 Memorandum from the Division of Trading and Markets regarding a March 17, 2011, meeting with representatives of Americans for Financial Reform (AFR)
Mar. 16, 2011 Memorandum from the Division of Trading and Markets regarding a March 16, 2011, telephonic meeting with Ed Rosen and Bob Colby on foreign bank issues
Mar. 9, 2010 Memorandum from the Division of Trading and Markets regarding a March 9, 2011 meeting with representatives of the Managed Funds Association
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. 2, 2011 Memorandum from the Office of Commissioner Paredes regarding a March 1, 2011, meeting with representatives of Nomura
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. 24, 2011 Memorandum from the Division of Trading and Markets Regarding a February 24, 2011 Meeting with Representatives of Better Markets, Inc.
Feb. 23, 2011 Memorandum from the Division of Trading and Markets regarding a February 23, 2011, meeting with representatives of Property Casualty Association of America
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. 15, 2011 Memorandum from the Division of Trading and Markets regarding a February 15, 2011, meeting with representatives of Bank of America Merrill Lynch
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. 11, 2011 Memorandum from the Division of Trading and Markets regarding a February 14, 2011 conference call with representatives of the Managed Funds Association
Feb. 11, 2011 Memorandum from the Office of the Chairman regarding a January 28, 2011, meeting with representatives of the Council of Institutional Investors
Feb. 4, 2011 Memorandum from the Division of Trading and Markets regarding a telephone meeting with Ed Rosen of Cleary Gottlieb Steen & Hamilton LLP
Feb. 4, 2011 Memorandum from the Division of Trading and Markets regarding a February 4, 2011, meeting with representatives of the Asset Management Group of the Securities Industry Financial Markets Association
Feb. 2, 2011 Memorandum from the Division of Trading and Markets regarding a February 2, 2011, conference call with Professor Darrell Duffie
Feb. 1, 2011 Memorandum from the Office of Commissioner Luis A. Aguilar regarding a January 31, 2011, meeting with representatives of Nomura
Jan. 31, 2011 Memorandum from the Office of Commissioner Walter regarding a January 31, 2011, meeting with representatives of Nomura Holding America Inc.
Jan. 20, 2010 Memorandum from the Division of Trading and Markets regarding a January 20, 2011 meeting with representatives of Citadel LLC
Jan. 14, 2011 Memorandum from the Division of Trading and Markets regarding a January 14, 2011 meeting with foreign bank representatives
Jan. 13, 2011 Memorandum from the Division of Trading and Markets regarding a January 13, 2011, meeting with representatives of the National Rural Utilities Cooperative Finance Corporation
Jan. 12, 2011 Memorandum from the Division of Trading and Markets regarding a January 12, 2011 meeting with representatives of the National Association of Regulatory Utility Commissioners
Dec. 21, 2010 Memorandum from the Division of Trading and Markets regarding a December 21, 2010, meeting with representatives of the Coalition of Derivatives End Users
Dec. 16, 2010 Memorandum from the Office of Commissioner Aguilar regarding a December 8, 2010, meeting with representatives of the Managed Funds Association
Dec. 8, 2010 Memorandum from the Office of Commissioner Walter regarding a December 8, 2010, meeting with representatives of the Managed Funds Association
Dec. 8, 2010 Memorandum from the Division of Trading and Markets regarding a Meeting with Representatives of the Managed Funds Association (MFA)

 

http://www.sec.gov/comments/s7-39-10/s73910.shtml

Modified: 10/16/2014