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"


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Date Received
Date Sort descending Letter Type Commenter Name
Meeting with SEC Officials 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
Meeting with SEC Officials 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
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a March 21, 2011, telephonic meeting with representatives of Northland Energy Trading LLC
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a March 18, 2011 Meeting with Representatives of Chatham Financial
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a March 17, 2011, meeting with representatives of Americans for Financial Reform (AFR)
Meeting with SEC Officials 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
Public Comment Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, U.S. Senate Committee on Homeland Security and Government Affairs
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a March 3, 2011, meeting with representatives of the Institute of International Bankers (IIB)
Meeting with SEC Officials Memorandum from the Office of Commissioner Paredes regarding a March 1, 2011, meeting with representatives of Nomura
Meeting with SEC Officials 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.
Public Comment Christopher J. Ailman, Chief Investment Officer, California State Teachers' Retirement System
Public Comment Gary DeWaal, Senior Managing Director and Newedge Group General Counsel, Newedge USA, LLC
Meeting with SEC Officials Memorandum from the Division of Trading and Markets Regarding a February 24, 2011 Meeting with Representatives of Better Markets, Inc.
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a February 23, 2011 meeting with representatives of the Property Casualty Insurers Association of America
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a February 23, 2011, meeting with representatives of Property Casualty Association of America
Public Comment American Benefits Council and Committee on Investment of Employee Benefit Assets
Public Comment Americans for Financial Reform
Public Comment Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers
Public Comment Christopher A. Klem, Ropes & Gray LLP
Public Comment Daniel F. C. Crowley, Partner, K&L Gates, on behalf of the Church Alliance
Public Comment David Carroll, Senior Counsel, American Express Company
Public Comment Dennis M. Kelleher, President & CEO; Stephen W. Hall, Securities Specialist; and Wallace C. Turbeville, Derivatives Specialist, Better Markets, Inc.
Public Comment Diana L. Preston, Deputy General Counsel, ABA Securities Association, Vice President and Senior Counsel, Center for Securities, Trust & Investments, American Bankers Association
Public Comment Frank Iacono, Partner, Riverside Risk Advisors LLC
Public Comment Gerald W. McEntee, Intenational President, American Federation of State, County and Municipal Employees
Public Comment Gus Sauter, Managing Director and Chief Investment Officer, Vanguard and John Hollyer, Principal and Head of Risk Management and Strategy Analysis, Vanguard
Public Comment Guus Warringa, Chief Counsel, APG Algemene Pensioen Groep NV, Amsterdam, Netherlands
Public Comment J. Stephen ("Stef") Zielezienski, Senior Vice President & General Counsel, American Insurance Association
Public Comment Jack A. Hartings, The Peoples Bank Co., Coldwater, Ohio
Public Comment Jennifer J. Kalb, Associate General Counsel, MetLife

Last Reviewed or Updated: Dec. 18, 2025