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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
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(Click here for meetings with SEC officials)
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| 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)
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| 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
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