Comment Text:
Meeting with Nomura
Tuesday, March 01, 2011
Memo from
Fajfar, Mark
CFTC Staff :
Jackie Mesa
Dan Berkovitz
Terry Arbit
Phyllis Dietz
Tom Smith
Mark Fajfar
Julian Hammar
Lee Ann Duffy
Natalie Markman Radhakrishnan
Warren Gorlick
Andrea Musalem
External Attendees :
Angie Karna (Nomura)
Heather Wingate (Nomura)
Eric Del Monaco (Nomura)
Ralph Mattone (Nomura)
David Moser (Nomura)
Brant Imperatore (Cypress Group)
Additional Information :
Nomura believes that, generally, the regulation of swap dealers that are active in various countries should focus on the swap dealers’ activities with counterparties that are US persons. Clearing and data reporting requirements should apply to swaps with US persons. The CFTC should endeavor to defer to home country regulation when non-US entities are well-regulated. Swaps between affiliates should not be considered in determining if any of the parties to the swaps is a swap dealer.