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External Meetings: Meeting with Morgan Stanley
Rulemaking(s):
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
CFTC Staff:
Gary Gensler
Gary Barnett
Dan Berkovitz
Dhaval Patel
Jeff Burns
Carl Kennedy
David Aron
Tim Karpoff
Sarah Josephson
Visitor(s):
Soo-Mi Lee
William McCoy
Anthony Cicia
Michael Stein
Organization(s):
Morgan Stanley
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Representatives from Morgan Stanley 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) when appropriate, defer to comparable foreign regulatory regimes; (3) harmonize the Commission’s swap rules with the security-based swap rules of the Securities and Exchange Commission; (4) through a rulemaking or interpretative guidance, address the application of transaction-level requirements on inter-affiliate transactions; and (5) implement the swap rules in a manner that does not create opportunities for regulatory arbitrage.