Comment Text:
We are trying to obtain an answer to a question in which we have received many mixed answers and that is in determining if a bank is a "SWAP DEALER".
The majority of out swap transactions are done through the London Clearing House therefore, making them our ultimate counterparty and credit risk.
So when calculating our swap transactions do we include these transactions which means that the LCH is considered a U.S. person to determine if we exceed the de minimis amount of $8 billion.
