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Comment for Proposed Rule 76 FR 29818

  • From: Sutherland Asbill & Brennan LLP Sutherland Asbill & Brennan LLP
    Organization(s):
    Committee of Annuity Insurers

    Comment No: 47899
    Date: 7/22/2011

    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.