Comments on Proposed Rule: Application of Certain Title VII Requirements to Security-Based Swap Transactions Connected with a Non-U.S. Person's Dealing Activity That Are Arranged, Negotiated, or Executed By Personnel Located in a U.S. Branch or Office or in a U.S. Branch or Office of an Agent

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Date Received
Date Letter Type Commenter Name
Public Comment Bert Fuqua, General Counsel, and Michael Loftus, Managing Director; Investment Bank Americas Legal, UBS AG
Meeting with SEC Officials Memorandum from the Office of Commissioner Michael S. Piwowar regarding an April 27, 2016, meeting with representatives of HSBC
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a February 4, 2016, meeting with representatives of HSBC
Public Comment Adam C. Cooper, Senior Managing Director and Chief Legal Officer, Citadel LLC, Chicago, Illinois
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a December 16, 2015, meeting with representatives of the International Swaps and Derivatives
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a November 9, 2015, meeting with representatives of HSBC
Meeting with SEC Officials Memorandum from the Office of Commissioner Michael S. Piwowar regarding an October 22, 2015, meeting with representatives of HSBC
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an October 14, 2015, meeting with representatives of Barclays
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an October 19, 2015, meeting with representatives of Citadel and Delta Strategy Group
Meeting with SEC Officials Memorandum from the Office of Commissioner Michael S. Piwowar regarding an October 19, 2015, meeting with representatives of Citadel and Delta Strategy Group
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an October 14, 2015, meeting with representatives of SIFMA AMG, BlackRock, Vanguard, Goldman Sachs Asset Management, and Russell
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a September 8, 2015, meeting with representatives of ISDA
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an August 28, 2015, meeting with representatives of the Institute of International Bankers and the Securities Industry and Financial Markets Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a July 23, 2015, meeting with representatives of SIFMA
Meeting with SEC Officials Memorandum from the Office of Commissioner Kara Stein regarding a July 24, 2105 meeting with representatives of the Managed Funds Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Michael S. Piwowar regarding a July 23, 2015, meeting with representatives of the Managed Funds Association
Public Comment Adam C. Cooper, Senior Managing Director and Chief Legal Officer, Citadel LLC, Chicago, Illinois
Public Comment Dan Waters, Managing Director, ICI Global
Public Comment David Geen, General Counsel, International Swaps and Derivatives Association, Inc.
Public Comment Dennis M. Kelleher, President & CEO, et al., Better
Public Comment Kenneth E. Bentsen, Jr., President & CEO, SIFMA, and Rich Foster, Senior Vice President & Senior Counsel for Regulatory and Legal Affairs, Financial Services Roundtable
Public Comment Mark A. Steffensen, Managing Director and General Counsel, HSBC Securities (USA) Inc.
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a June 24, 2015, meeting with representatives of Goldman Sachs
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a June 25, 2015, meeting with representatives of The Wholesale Markets Brokers' Association, Americas
Public Comment Sarah A. Miller, Chief Executive Officer, Institute of International Bankers
Public Comment Stuart J. Kaswell, Executive Vice President, Managing Director & General Counsel, Managed Funds Association
Public Comment Sullivan & Cromwell LLP
Public Comment Timothy W. Cameron, Esq., Managing Director, Head, Asset Management Group, and Laura Martin Managing Director and Associate General Counsel, Asset Management Group; Securities Industry and Financial Markets Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a June 29, 2015, meeting with a representative of Davis Polk & Wardwell
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a June 30, 2015, meeting with representatives of UBS

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-06-15
Release Number
34-74834
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