Comment Text:
75 FR 71379 is designed to define the registration process for Swap Dealers and Major Swap Participants. The footnotes in 75 FR 71379 show me there are exceptions for required registration:
2 - Major Swap Participant
(A) In General
(iii)
(II) Footnote 9 D) Exclusions
It is up to the Commission to define Swap Dealers and Major Swap Participants. If an entity or person fits the Commission's definition then registration is required. Footnote 9 D) Exclusions undermines the Commission's purpose by overriding and ignoring the Commission's authority
3 Associated Person of a Swap Dealer or Major Swap Participant
(A) In General
(ii) footnote 10
Again making exceptions for clerical and ministries undermines the purpose of the Commission. Footnote 10 is opening the door to start raising money for derivatives with religious donations. We have already seen many taxpayers loose big on retirement plans, and I am sure the backlash to religious organizations that made bets in the market instead using donations intended to help the less fortunate.
