Comment Text:
Attached is SVIA’s comment letter on the reopening of the comment period for “Acceptance of Public Submissions Regarding the Study of Stable Value Contracts” (Release No.34-67927) (File No. S7-32-11). SVIA’s comments letter uses the Commissions’ frame work and logic in developing the Final Rule for swaps to further explain why stable value contracts are not swaps. The SVIA comment letter also discusse how the swap regulatory frame work is unnecessary and unworkable for stable value contracts.
