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Ex Parte Meeting for Proposed Rule 75 FR 80174

  • Title:
    Definitions Meeting w/ Financial Services Roundtable

    Ex Parte No: 419
    Date: 10/19/2011

    Meeting Date:

    Wednesday, October 19, 2011

    CFTC Staff:

    Jeff Burns
    Mark Fajfar
    Stephen Kane
    Cam Nunery


    The Financial Services Roundtable
    Capital One
    CIT Capital Markets
    CIT Group
    FTN Financial/First Tennessee Bank
    Toyota Financial
    Union Bank
    US Bank
    Arnold & Porter
    Latham & Watkins

    External Attendees:

    Kenny Abramowitz, Capital One
    Karl C. Haddeland, CIT Group
    William Harvey, Union Bank
    Robert Hatch, The Financial Services Roundtable
    Phillip Lavigne, The Financial Services Roundtable
    Bob Lendino, BB&T
    Ellen Marks, Latham & Watkins
    Peter Phelan, CIT Capital Markets
    Leo Pylypec, FTN Financial/First Tennessee Bank
    Bill Sakkab, Capital One
    Joe Tessmer, US Bank
    Dan Waldman, Arnold & Porter representing Toyota Financial

    Additional Information:

    The meeting discussed points made by the Financial Services Roundtable in a comment letter submitted on October 17, 2011, primarily regarding the exclusion in the definition of swap dealer for swaps entered into by insured depository institutions in connection with the origination of loans.  The Roundtable is particularly concerned by any requirement that such swaps be entered into contemporaneously with the origination of a loan.  Also, they believe any swap closely linked to the loan should be covered by the exclusion (rather than limiting the exclusion to swaps related to the financial terms of the loan).  The Roundtable also pointed out that the costs to an insured depository institution from being designated as a swap dealer are potentially more significant as a result of the requirement that such institutions not engage in certain proprietary trading.

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