Comment Text:
The Credit Union National Association (CUNA) appreciates the opportunity to comment on a joint proposal by the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) to define “swap dealer,” “securities swap dealer,” and other terms. By way of background, CUNA is the largest credit union advocacy organization in the country, representing approximately 90 percent of our nation's nearly 7,600 state and federal credit unions, which serve approximately 93 million members.
A copy of CUNA's comment letter regarding RIN 3235–AK65 (Release No. 34-63452; File No. S7-39-10) is attached.
