Meeting Date:
Thursday, September 22, 2011
CFTC Staff:
Ananda Radhakrishnan
Gary Barnett
Jackie Mesa
Claire Noakes
Camden Nunery
Thelma Diaz
Natalie Markman Radhakrishnan
Lee Ann Duffy
Jason Shafer
David Van Wagner
Warren Gorlick
Jeff Steiner
Laura Astrada
Carl Kennedy
Susan Berkowitz (via telephone)
Edwin Yoshimura (via telephone)
Organization(s):
Goldman Sachs & Co.
External Attendees:
Kenneth M. Connolly
Tom Riggs
Dirk Pruis
Liz Martin
William Iwashchuk
Additional Information:
Representatives from Goldman Sachs & Co. discussed the extraterritorial application of the Dodd-Frank Act (Act) requirements for swap dealers. Specifically, the representatives asked the Commission to: (1) issue guidance on the extraterritorial reach of the Act in order to provide clarity to market participants; (2) when appropriate, defer to comparable foreign regulatory regimes; (3) harmonize the Commission’s swap rules with the security-based swap rules of the Securities and Exchange Commission; and (4) through a rulemaking or interpretative guidance, address the application of transaction-level requirements on inter-affiliate transactions.