Comment Text:
Attached please find ISDA's and SIFMA's comments on the CFTC's proposed rules regarding: (1) RIN 3038–AD08 - Real-Time Public Reporting of Swap Transaction Data; (2) RIN 3038–AD19 - Swap Data Recordkeeping and Reporting Requirements; and (3) RIN 3038–AC96 - Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants.
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