Comment Text:
The attached comments address all aspects of the Commission’s proposed rulemakings related to swaps between affiliated entities within a corporate group, including, but not limited to, the following proposed rulemakings:
(i) Further Definition of "Swap,'' "Security-Based Swap,'' and "Security-Based Swap Agreement''; Mixed Swaps; Security-Based Swap Agreement Recordkeeping, 76 Fed. Reg. 29818 (proposed May 23, 2011) [RIN 3038-AD46] (“Further Definition of “Swap” Release”);
(ii) Further Definition of “Swap Dealer,” “Security-Based Swap Dealer,” “Major Swap Participant,” “Major Security-Based Swap Participant” and “Eligible Contract Participant”, 75 Fed. Reg. 80174 (proposed Dec. 21, 2010) [RIN 3235-AK65] (“Further Definition of “Swap Dealer” Release”);
(iii) Registration of Swap Dealers and Major Swap Participants, 75 Fed. Reg. 71379 (proposed Nov. 23, 2010) [RIN 3038-AC95] (“Registration Release”);
(iv) Capital Requirements of Swap Dealers and Major Swap Participants, 76 Fed. Reg. 27802 (proposed May 12, 2011) [RIN 3038-AD54] (“Capital Release”);
(v) Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants, 76 Fed. Reg. 23732 (proposed April 28, 2011) [RIN 3038-AC97] (“Margin Release”);
(vi) Position Limits for Derivatives, 76 Fed. Reg. 4752 (proposed Jan. 26, 2011) [RIN 3038-AD15 and 3038-AD16] (“Position Limits Release”);
(vii) End-User Exception to Mandatory Clearing of Swaps, 75 Fed. Reg. 80747 (proposed Dec. 23, 2010) [RIN 3038-AD10] (“End-User Release”);
(viii) Swap Trading Relationship Documentation Requirements for Swap Dealers and Major Swap Participants, 76 Fed. Reg. 6715 (proposed Feb. 8, 2011) [RIN 3038-AC96] (“Documentation Release”);
(ix) Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants, 75 Fed. Reg. 81519 (proposed Dec. 28, 2010) [RIN 3038-AC96] (“Portfolio Reconciliation Release”);
(x) Real-Time Public Reporting of Swap Transaction Data, 75 Fed. Reg. 76140 (proposed Dec. 7, 2010) [RIN 3038-AD08] (“Real-Time Reporting Release”); and
(xi) Swap Data Recordkeeping and Reporting Requirements, 75 Fed. Reg. 76574 (proposed Dec. 8, 2010) [RIN 3038-AD19] (“Swap Data Recordkeeping Release”).
