Comment Text:
Attached please find the comment letter jointly submitted by the Institute of International Bankers (IIB) and the European Banking Federation (EBF) on the above-referenced rulemaking. The letter is identical to the letter submitted to the other Agencies on the same subject, except that we have inserted in the subject line of the letter the complete CFTC RIN number as published in the Federal Register and included the complete Federal Register citation to the CFTC proposal in footnote 1 of the letter. The IIB and EBF appreciate the opportunity to comment on the proposal.