Comment Text:
Re: File No. S7-16-11
Further Definition of “Swap,” “Security-Based Swap,” and “Security-Based Swap Agreement”; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
(Securities and Exchange Commission Release Nos. 33-9204; 34-64372)
On behalf of the Committee of Annuity Insurers we are submitting the attached comment letter on the SEC and CFTC joint proposed rules on the definition of "swap" and "security-based swap." Please contact me if you have any trouble accessing the comment letter.