Meeting Date:
Wednesday, October 5, 2011
CFTC Staff:
Gary Barnett
Carl Kennedy
Organization(s):
JP Morgan Chase & Co.
External Attendees:
Jeremy Barnum
Don Thompson
Thomas Koonce
Additional Information:
Representatives from JPMorgan Chase & 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) permit the registration and regulation of foreign bank branches as swap dealers; (3) when appropriate, defer to comparable foreign regulatory regimes; (4) implement the swap rules in a manner that does not create opportunities for regulatory arbitrage; and (5) treat the margin requirement as a transaction-level requirement.
