Comment Text:
75 FR 80638
I would suggest a minimum comprehension requirement on the client of a swap dealer. A client should be qualified to process a swap deal. The reason a client would want a swap dealer, because he or she does not have the time to acquire all material information to make a sound rational decision.
All parties involved in a swap deal must understand how the swap works, and the amount of liability being assumed.
If the swap dealer's client loses big, because he or she has no idea what the liabilities of the swap deal were assumed despite the swap dealer providing all material information then the swap dealer should not be accused of fraud or other crime.
