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Business Conduct Standards with Counterparties
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The Commission has issued proposed rules to implement the Dodd-Frank Wall Street Reform and Consumer Protection Act, and is seeking input on these rules from the public.
A list of proposed rules for this topic, along with other related Federal Register notices, is provided below. Members of the public are encouraged to review proposed rules, and offer comment by clicking the associated "Comment File" link.
Additional information regarding Business Conduct Standards w/ Counterparties is provided below, including factsheets for each proposed rule, and details of meetings held between CFTC staff and outside parties.
Related Federal Register Releases
Final Rule: 77 FR 9734 // PDF Version
2/17/2012
17 CFR Parts 4 and 23 Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties
Effective Date: April 17, 2012Proposed Rule: 75 FR 80638 // PDF Version
12/22/2010
17 CFR Parts 23 and 155 Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties
Comment File - Extended Date: 6/3/2011Additional Information
EBSA Letter to CFTC Regarding: Business Conduct Standards Rules
Fact Sheet: Final Rules Regarding Business Conduct Standards for Swap Dealers and Major Swap Participants Dealing with Counterparties
Q&A: Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties Final RulemakingEvent: Open Meeting on Three Final Rules, One Proposed Rule and a Delegation of Authority Order
Fact Sheet: Proposed Rules Regarding Business Conduct Standards for Swap Dealers and Major Swap Participants Dealing with Counterparties
Q&A: External Business Conduct Standards for Swap Dealers and Major Swap Participants Dealings with CounterpartiesEvent: Open Meeting on Seventh Series of Proposed Rules under the Dodd-Frank Act
Date
MEETING WITH
REGARDING RULEMAKING
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
Markit
arkitSERV
M
Markit Valuations
DTCC
Latham & Watkins
arkitSERV
M
Markit Valuations
DTCC
Latham & Watkins
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
General
V. Capital & Margin
General
US Bank
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
General
IV. Business Conduct Standards – Internal
General
BP
II. Definitions
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
XXVI. Position Limits
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
XXVI. Position Limits
Consumer Federation of America
Better Markets, Inc.
Better Markets, Inc.
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America
Better Markets, Inc.
Better Markets, Inc.
II. Definitions
III. Business Conduct Standards w/ Counterparties
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America ("CFA")
Better Markets, Inc.
Better Markets, Inc.
III. Business Conduct Standards w/ Counterparties
BlackRock
II. Definitions
III. Business Conduct Standards w/ Counterparties
VIII. Process for Review of Swaps
General
III. Business Conduct Standards w/ Counterparties
VIII. Process for Review of Swaps
General
Commodity Markets Oversight Council Coalition:
New England Fuel Institute
Maryknoll
Better Markets
American Public Gas Association
Petroleum Marketers Association of America
American Feed Industry Association
National Farmers Union
Airlines for America
National Council of Chain Restaurants
Americans for Financial Reform
Institute for Agriculture & Trade Policy
Clark & Weinstock
Consumer Federation of America
New York Oil Heating Association
University of Maryland
American Bakers' Association
National Association of Shell Marketrs
American Trucking Association
Institute for Agriculture & Trade Policy
New England Fuel Institute
Maryknoll
Better Markets
American Public Gas Association
Petroleum Marketers Association of America
American Feed Industry Association
National Farmers Union
Airlines for America
National Council of Chain Restaurants
Americans for Financial Reform
Institute for Agriculture & Trade Policy
Clark & Weinstock
Consumer Federation of America
New York Oil Heating Association
University of Maryland
American Bakers' Association
National Association of Shell Marketrs
American Trucking Association
Institute for Agriculture & Trade Policy
III. Business Conduct Standards w/ Counterparties
XXVI. Position Limits
XXVIII. Volcker Rule
General
XXVI. Position Limits
XXVIII. Volcker Rule
General
Goldman Sachs
III. Business Conduct Standards w/ Counterparties
General
General
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
American Federation of State, County and Municipal Employees (AFSCME)
AFL-CIO Office of Investment
Americans for Financial Reform (AFR)
American Federation of State, County and Municipal Employees (AFSCME)
AFL-CIO Office of Investment
III. Business Conduct Standards w/ Counterparties
Committee on Investment of Employee Benefit Assets (CIEBA)
American Benefits Council (ABC)
European Pension Federation (EFRP)
Franklin Advisors, Inc.
General Motors Pension Fund
NISA Investment Advisors
American Benefits Council (ABC)
European Pension Federation (EFRP)
Franklin Advisors, Inc.
General Motors Pension Fund
NISA Investment Advisors
III. Business Conduct Standards w/ Counterparties
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
VI. Segregation and Bankruptcy
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
General
General
BlackRock
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA
SIFMA Asset Management Group
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA
SIFMA Asset Management Group
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
VI. Segregation and Bankruptcy
BlackRock
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA
III. Business Conduct Standards w/ Counterparties
ISDA
Morgan Stanley
J.P. Morgan
Goldman Sachs
Mayer Brown
Morgan Stanley
J.P. Morgan
Goldman Sachs
Mayer Brown
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
VI. Segregation and Bankruptcy
BlackRock
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA Asset Management Group
Davis Polk
Fidelity
GM Asset Management
Goldman Sachs Asset Management
SIFMA Asset Management Group
III. Business Conduct Standards w/ Counterparties
American Benefits Council (ABC)
The Committee on Investment of Employee Benefit Assets (CIEBA)
General Motors Investment Managment Corp. (GMIMCO)
Xerox
Weyerhaeuser
Chrysler
Lockheed Martin
IBM
Venable
Skadden
Davis & Harman
The Committee on Investment of Employee Benefit Assets (CIEBA)
General Motors Investment Managment Corp. (GMIMCO)
Xerox
Weyerhaeuser
Chrysler
Lockheed Martin
IBM
Venable
Skadden
Davis & Harman
III. Business Conduct Standards w/ Counterparties
Skadden
GMIMCO
Xerox
Lockheed Martin
IBM
ABC
CIEBA
Davis & Harman, behalf of Chrysler
Chris Condeluci Venable, on behalf of Chrysler
Jordan Moon Chrysler
Fred Miller, Weyerhaeuser
GMIMCO
Xerox
Lockheed Martin
IBM
ABC
CIEBA
Davis & Harman, behalf of Chrysler
Chris Condeluci Venable, on behalf of Chrysler
Jordan Moon Chrysler
Fred Miller, Weyerhaeuser
III. Business Conduct Standards w/ Counterparties
BlackRock
Davis Polk
Fidelity
Goldman Sachs Assest Managment
SIFMA
SIFMA Assest Managment Group
Davis Polk
Fidelity
Goldman Sachs Assest Managment
SIFMA
SIFMA Assest Managment Group
III. Business Conduct Standards w/ Counterparties
Skadden, Arps, Slate, Meagher & Flom LLP
General Motors Investment Management Corporation Outsources (GMIMCO)
Xerox
Lcokheed Martin
IBM
ABC
Committee on the Investment of Employee Benefit Assets (CIEBA)
Davis-Harman
Venable
General Motors Investment Management Corporation Outsources (GMIMCO)
Xerox
Lcokheed Martin
IBM
ABC
Committee on the Investment of Employee Benefit Assets (CIEBA)
Davis-Harman
Venable
III. Business Conduct Standards w/ Counterparties
California Public Employees' Retirement System
Teachers Retirement System of Texas
State of Wisconsin Investment Board
Lussier, Gregor, Vienna & Assoiciates
Teachers Retirement System of Texas
State of Wisconsin Investment Board
Lussier, Gregor, Vienna & Assoiciates
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
VI. Segregation and Bankruptcy
American Benefits Council
Committee on Investment of Employee Benefits
NISA Investment Advisors
Skadden, Arps
Xerox
Lockheed Martin
IBM
Venable
Committee on Investment of Employee Benefits
NISA Investment Advisors
Skadden, Arps
Xerox
Lockheed Martin
IBM
Venable
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
Americans for Financial Reform (AFR)
III. Business Conduct Standards w/ Counterparties
Americans for Financial Reform (AFR)
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
Better Markets
Americans for Financial Reform (AFR)
Better Markets
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
III. Business Conduct Standards w/ Counterparties
Califiornia Public Employees' Retirement System (CalPERS)
Colorado Public Employees' Retirement Association (Colorado PERA)
Missouri State Employees' Retirement System (MOSERS)
State of Wisconsin Investment Board (SWIB)
Teacher Retirement System of Texas (TRS)
Colorado Public Employees' Retirement Association (Colorado PERA)
Missouri State Employees' Retirement System (MOSERS)
State of Wisconsin Investment Board (SWIB)
Teacher Retirement System of Texas (TRS)
III. Business Conduct Standards w/ Counterparties
JP Morgan Chase & Co.
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
The Church Alliance
II. Definitions
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
Senator Johnson and Representative Frank
III. Business Conduct Standards w/ Counterparties
Morgan Stanley
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
Better Markets
Americans for Financial Reform (AFR)
Better Markets
III. Business Conduct Standards w/ Counterparties
Teacher Retirement System of Texas (TRS)
Missouri State Employees' Retirement System (MOSERS)
California Public Employees' Retirement System (CalPERS)
State of Wisconsin Investment Board (SWIB)
Lussier, Gregor, Vienna & Assoc.
NISA Investment Advisers (NISA)
Delta Strategy Group (DSG)
Missouri State Employees' Retirement System (MOSERS)
California Public Employees' Retirement System (CalPERS)
State of Wisconsin Investment Board (SWIB)
Lussier, Gregor, Vienna & Assoc.
NISA Investment Advisers (NISA)
Delta Strategy Group (DSG)
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
Better Markets
Americans for Financial Reform (AFR)
Better Markets
III. Business Conduct Standards w/ Counterparties
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
Committee on Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
Church Alliance
II. Definitions
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
Russell Investments (Russell)
III. Business Conduct Standards w/ Counterparties
Andrew Kalotay Associates, Inc.
III. Business Conduct Standards w/ Counterparties
City and County of San Francisco (SF)
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
III. Business Conduct Standards w/ Counterparties
American Benefits Council (ABC)
The Committee on the Investment of Employee Benefit Assets (CIEBA)
The Committee on the Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
Senator Carl Levin
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
IV. Business Conduct Standards – Internal
Consumer Federation of America (CFA)
Americans for Financial Reform (AFR)
Americans for Financial Reform (AFR)
III. Business Conduct Standards w/ Counterparties
Tennessee Office of the Comptroller of the Treasury (TOCT)
III. Business Conduct Standards w/ Counterparties
Delta Strategy Group (DSG)
III. Business Conduct Standards w/ Counterparties
National Futures Association (NFA)
Municipal Securities Rulemaking Board (MSRB)
Municipal Securities Rulemaking Board (MSRB)
III. Business Conduct Standards w/ Counterparties
Securities Industry and Financial Markets Association (“SIFMA”)
Goldman Sachs
Morgan Stanley
Goldman Sachs
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
Securities Industry and Financial Markets Association (“SIFMA”)
Goldman Sachs
Morgan Stanley
Goldman Sachs
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
MOSERS
COPERA
SWIB
VRS
CalPERS
TRST
COPERA
SWIB
VRS
CalPERS
TRST
III. Business Conduct Standards w/ Counterparties
CalPERS
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
XXVI. Position Limits
V. Capital & Margin
XXVI. Position Limits
Missouri State Employees Retirement System (MOSERS)
Public Employees’ Retirement Association of Colorado (COPERA)
State of Wisconsin Investment Board (SWIB)
Virginia Retirement Systems (VRS)
California Public Employees' Retirement System (CalPERS)
Teachers Retirement System of Texas (TRST)
Delta Strategy Group (DSG)
Lussier, Gregor, Vienna & Associates
Public Employees’ Retirement Association of Colorado (COPERA)
State of Wisconsin Investment Board (SWIB)
Virginia Retirement Systems (VRS)
California Public Employees' Retirement System (CalPERS)
Teachers Retirement System of Texas (TRST)
Delta Strategy Group (DSG)
Lussier, Gregor, Vienna & Associates
III. Business Conduct Standards w/ Counterparties
Skadden Arps
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
IV. Business Conduct Standards – Internal
Mizuho Securities USA, Inc. (MSUSA)
Sherman & Sterling LLP (Sherman & Sterling)
Sapient Global Markets (Sapient)
Sherman & Sterling LLP (Sherman & Sterling)
Sapient Global Markets (Sapient)
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
Securities Industry and Financial Markets Association (“SIFMA”)
Goldman Sachs
Morgan Stanley
Nomura
Deutsche Bank
Goldman Sachs
Morgan Stanley
Nomura
Deutsche Bank
III. Business Conduct Standards w/ Counterparties
American Benefits Counsel (ABC)
Davis Harman
Davis Harman
III. Business Conduct Standards w/ Counterparties
American Benefits Council (ABC), Committee on Investment of Employee Benefit Assets (CIEBA), Skadden Arps, Lockheed Martin, Venable, Chrysler, Xerox, IBM, Ford, Weyerhaeuser, General Motors (GM), NISA Investment Advisors, Davis Harman
III. Business Conduct Standards w/ Counterparties
Skadden
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
Securities Industry and Financial Markets Association (“SIFMA”)
Goldman Sachs
Morgan Stanley
Nomura
Deutsche Bank
Goldman Sachs
Morgan Stanley
Nomura
Deutsche Bank
III. Business Conduct Standards w/ Counterparties
Skadden, Arps, Slate, Meagher & Flom LLP (Skadden)
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
Reval
LTD Group (LTD)
LTD Group (LTD)
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
V. Capital & Margin
BlackRock
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
IX. Governance & Possible Limits
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
IX. Governance & Possible Limits
Rabobank
Davis Polk
Davis Polk
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
General
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
General
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
IV. Business Conduct Standards – Internal
Working Group of Commercial Energy Firms
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
General
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
General
Credit Suisse, Deutsche Bank, Citi, JP Morgan, Barclays, Morgan Stanley, Goldman Sachs, UBS
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
XVII. Data Recordkeeping
XVIII. Real Time Reporting
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
XVII. Data Recordkeeping
XVIII. Real Time Reporting
U.S. Department of Labor, Employee Benefits Security Administration (EBSA)
III. Business Conduct Standards w/ Counterparties
Morgan Stanely
II. Definitions
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
Institute of International Bankers
Royal Bank of Canada
Barclays Capital
BNP Paribas
Credit Suisse
Deutsche Bank
HSBC
Rabobank
Societe Generale
The Royal Bank of Scotland
UBS
Clearly Gottlieb
Royal Bank of Canada
Barclays Capital
BNP Paribas
Credit Suisse
Deutsche Bank
HSBC
Rabobank
Societe Generale
The Royal Bank of Scotland
UBS
Clearly Gottlieb
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
XVII. Data Recordkeeping
XVIII. Real Time Reporting
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
XIII. SEF Registration
XVIII. Real Time Reporting
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
XIII. SEF Registration
XVIII. Real Time Reporting
Sullivan & Cromwell LLP (Sullivan)
Canada Pension Plan Investment Board (CPPIB)
Canada Pension Plan Investment Board (CPPIB)
III. Business Conduct Standards w/ Counterparties
Winston & Strawn LLP, United Technologies, U.S. Steel & Carnegie Pension Fund, NISA Investment Advisors, Skadden, Arps, American Benefits Council, and the Committee on Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
IV. Business Conduct Standards – Internal
XIII. SEF Registration
XVIII. Real Time Reporting
Winston & Strawn LLP
United Technologies
U.S. Steel & Carnegie Pension Fund
NISA Investment Advisors
Skadden, Arps
American Benefits Council
Committee on Investment of Employee Benefit Assets (CIEBA)
United Technologies
U.S. Steel & Carnegie Pension Fund
NISA Investment Advisors
Skadden, Arps
American Benefits Council
Committee on Investment of Employee Benefit Assets (CIEBA)
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
XIII. SEF Registration
XVIII. Real Time Reporting
NISA Investment Advisors
United Technologies
Committee on Investment of Employee Benefit Assests(CIEBA)
American Benefits Council (ABC)
U.S. Steel
Winston
Skadden
United Technologies
Committee on Investment of Employee Benefit Assests(CIEBA)
American Benefits Council (ABC)
U.S. Steel
Winston
Skadden
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
XIII. SEF Registration
XVIII. Real Time Reporting
Winston & Strawn LLP
United Technologies
U.S. Steel & Carnegie Pension Fund
NISA Investment Advisors, LLC
Davis & Harman LLP
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
Skadden, Arps
United Technologies
U.S. Steel & Carnegie Pension Fund
NISA Investment Advisors, LLC
Davis & Harman LLP
American Benefits Council (ABC)
Committee on Investment of Employee Benefit Assets (CIEBA)
Skadden, Arps
III. Business Conduct Standards w/ Counterparties
National Rural Electric Cooperative Association
American Public Power Association
American Public Gas Association
Large Public Power Council
ACES Power Marketing
Schiff Hardin LLP
Wilmer Cutler Pickering Hale and Dorr LLP
American Public Power Association
American Public Gas Association
Large Public Power Council
ACES Power Marketing
Schiff Hardin LLP
Wilmer Cutler Pickering Hale and Dorr LLP
III. Business Conduct Standards w/ Counterparties
General Motors (GM)
Davis & Harman (DM)
NISA Investment Advisors (NISA)
Association for Financial Professionals (AFP)
Skadden (S)
American Benefits Council (ABC)
Winston & Strawn (WS)
Davis & Harman (DM)
NISA Investment Advisors (NISA)
Association for Financial Professionals (AFP)
Skadden (S)
American Benefits Council (ABC)
Winston & Strawn (WS)
II. Definitions
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
XVI. Swap Data Repositories Registration
III. Business Conduct Standards w/ Counterparties
VI. Segregation and Bankruptcy
XVI. Swap Data Repositories Registration
General Motors (GM)
NISA Investment Advisors (NISA)
Association for Financial Professionals (AFP)
American Benefits Council (ABC)
Skadden (S)
Winston & Strawn (WS)
NISA Investment Advisors (NISA)
Association for Financial Professionals (AFP)
American Benefits Council (ABC)
Skadden (S)
Winston & Strawn (WS)
II. Definitions
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
CIEBA
American Benefits Council
American Benefits Council
II. Definitions
III. Business Conduct Standards w/ Counterparties
XVI. Swap Data Repositories Registration
XVII. Data Recordkeeping
III. Business Conduct Standards w/ Counterparties
XVI. Swap Data Repositories Registration
XVII. Data Recordkeeping
The Committee of Annuity Insurers
III. Business Conduct Standards w/ Counterparties
American Benefits Council
Committee on Investment of Employee Benefit Assets (CIEBA)
General Motors
Boeing
United Technologies Corporation (UTC)
NISA Investment Advisors
Committee on Investment of Employee Benefit Assets (CIEBA)
General Motors
Boeing
United Technologies Corporation (UTC)
NISA Investment Advisors
III. Business Conduct Standards w/ Counterparties
American Benefits Council
Specialists In Employee Benefit Administration, Ltd. (SIEBA)
Specialists In Employee Benefit Administration, Ltd. (SIEBA)
III. Business Conduct Standards w/ Counterparties
Natural Gas Supply Association
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
VI. Segregation and Bankruptcy
VIII. Process for Review of Swaps
XI. End-user Exception
XXVI. Position Limits
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
VI. Segregation and Bankruptcy
VIII. Process for Review of Swaps
XI. End-user Exception
XXVI. Position Limits
Counterparty Risk Management Policy Group (CRMPG)
Goldman Sachs
Goldman Sachs
III. Business Conduct Standards w/ Counterparties
American Benefits Council
III. Business Conduct Standards w/ Counterparties
The National Futures Association (NFA)
I. Registration
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
III. Business Conduct Standards w/ Counterparties
XIII. SEF Registration
XVIII. Real Time Reporting
Consumer Federation of America
II. Definitions
III. Business Conduct Standards w/ Counterparties
III. Business Conduct Standards w/ Counterparties
American Benefits Council
General Dynamics
GM Asset Management
NISA Investment Advisors LLC
CIEBA
Davis & Harman LLP
Skadden
General Dynamics
GM Asset Management
NISA Investment Advisors LLC
CIEBA
Davis & Harman LLP
Skadden
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
IX. Governance & Possible Limits
XI. End-user Exception
XVI. Swap Data Repositories Registration
XVII. Data Recordkeeping
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
IX. Governance & Possible Limits
XI. End-user Exception
XVI. Swap Data Repositories Registration
XVII. Data Recordkeeping
Morgan Stanley
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
Morgan Stanley
I. Registration
II. Definitions
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
II. Definitions
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
National Consumers League
III. Business Conduct Standards w/ Counterparties
XXVI. Position Limits
XXVI. Position Limits
National Council of Farmer Cooperatives
Land O'Lakes
Growmark
Dairy Farmers of America
CHS, Inc.
Land O'Lakes
Growmark
Dairy Farmers of America
CHS, Inc.
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
XI. End-user Exception
XIX. Agricultural Swaps
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
XI. End-user Exception
XIX. Agricultural Swaps
Jefferies and Company, Inc.
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
VII. DCO Core Principles
IX. Governance & Possible Limits
XII. DCM Core Principles
XVIII. Real Time Reporting
IV. Business Conduct Standards - Internal
VII. DCO Core Principles
IX. Governance & Possible Limits
XII. DCM Core Principles
XVIII. Real Time Reporting
Coalition for Derivatives End Users
II. Definitions
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
VII. DCO Core Principles
XVII. Data Recordkeeping
XVIII. Real Time Reporting
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards - Internal
V. Capital & Margin
VII. DCO Core Principles
XVII. Data Recordkeeping
XVIII. Real Time Reporting
Groom Law Group
National Association of State Retirement Administrations, NASRA
National Council on Teacher Retirement
Mosier's
State Workforce Investment Board (SWIB)
National Association of State Retirement Administrations, NASRA
National Council on Teacher Retirement
Mosier's
State Workforce Investment Board (SWIB)
III. Business Conduct Standards w/ Counterparties
Americans for Financial Reform
II. Definitions
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
VII. DCO Core Principles
VIII. Process for Review of Swaps
X. Systemically Important DCO Rules
XI. End-user Exception
XII. DCM Core Principles
XIII. SEF Registration
XVII. Data Recordkeeping
XVIII. Real Time Reporting
XXVI. Position Limits
III. Business Conduct Standards w/ Counterparties
V. Capital & Margin
VII. DCO Core Principles
VIII. Process for Review of Swaps
X. Systemically Important DCO Rules
XI. End-user Exception
XII. DCM Core Principles
XIII. SEF Registration
XVII. Data Recordkeeping
XVIII. Real Time Reporting
XXVI. Position Limits
International Swaps and Derivatives Association, Inc., ISDA
Mayer Brown
JPMorgan Chase & Co.
Morgan Stanley
Mayer Brown
JPMorgan Chase & Co.
Morgan Stanley
III. Business Conduct Standards w/ Counterparties
Securities Industry & Financial Markets Association (SIFMA)
III. Business Conduct Standards w/ Counterparties
Southwest Airlines
III. Business Conduct Standards w/ Counterparties
XI. End-user Exception
XI. End-user Exception
National Association of College and University Business Officers (NACUBO)
III. Business Conduct Standards w/ Counterparties
National Association of Treasurers (TN, CT)
National Association of State Auditors, Comptrollers and Treasurers (MD, WA)
Government Finance Officers Association (NYC,Centur, MTA, Sacramento Utility, Empire State Developement Corporation)
National Association of State Auditors, Comptrollers and Treasurers (MD, WA)
Government Finance Officers Association (NYC,Centur, MTA, Sacramento Utility, Empire State Developement Corporation)
III. Business Conduct Standards w/ Counterparties
State of Wisconsin Investment Board (SWIB)
Iowa Public Employees' Retirement System (IPERS)
Lussier, Gregor, Vienna & Associates (CGVA)
National Council on Teacher Retirement (NCTR)
Missouri State Employees' Retirement System (MIPERS)
PA Public Employees' Retirement System (PAPERS)
State of Maryland, Financial Policy
California Public Employees' Retirement System (CALPERS)
State of Wisconsin Investment Board, Fixed Income Portfolio
Iowa Public Employees' Retirement System (IPERS)
Lussier, Gregor, Vienna & Associates (CGVA)
National Council on Teacher Retirement (NCTR)
Missouri State Employees' Retirement System (MIPERS)
PA Public Employees' Retirement System (PAPERS)
State of Maryland, Financial Policy
California Public Employees' Retirement System (CALPERS)
State of Wisconsin Investment Board, Fixed Income Portfolio
III. Business Conduct Standards w/ Counterparties
Air Transport Control (ATA)
Continental Airlines
Alaska Air Group
United Airlines
Continental Airlines
Alaska Air Group
United Airlines
III. Business Conduct Standards w/ Counterparties
American Public Gas Association (APGA)
Municipal Gas Authority of Georgia
Colorado Springs Ultilities
Municipal Gas Authority of Georgia
Colorado Springs Ultilities
III. Business Conduct Standards w/ Counterparties
Consumer Federation of America (CFA)
American Federation of State, County and Municipal Employees (AFSCME)
Service Employees International Union (SEIU)
American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)
American Federation of State, County and Municipal Employees (AFSCME)
Service Employees International Union (SEIU)
American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)
III. Business Conduct Standards w/ Counterparties
Intercontinental Exchange (ICE)
III. Business Conduct Standards w/ Counterparties
Municipal Securities Rulemaking Board (MSRB)
III. Business Conduct Standards w/ Counterparties
Date
SUBMISSION
01/11/2012
11/03/2011
11-3-11 AFR CFA CFTC Business Conduct Letter_1128 
From External Meeting on 11/3/2011
From External Meeting on 11/3/2011
10/05/2011
Re: SEC-CFTC and Pension Fund Meeting on Business Conduct Standards
CALPERS, CPERA, WIB, TRST, MSERS, From External Meeting on 10/5/2011
CALPERS, CPERA, WIB, TRST, MSERS, From External Meeting on 10/5/2011
10/05/2011
Documents from 10/5 meeting
JP Morgan, From External Meeting on 10/5/2011
JP Morgan, From External Meeting on 10/5/2011
10/04/2011
Church Alliance Cover Letter
Church Alliance, From External Meeting on 10/4/2011
Church Alliance, From External Meeting on 10/4/2011
10/04/2011
The Church Alliance Follow Up to Meeting on September 9 at CFTC
Church Alliance, From External Meeting on 10/4/2011
Church Alliance, From External Meeting on 10/4/2011
10/04/2011
Special Entity Definition – Opt-In for Church Plans
Church Group, From External Meeting on 10/4/2011
Church Group, From External Meeting on 10/4/2011
10/04/2011
Church Plans – Definitions and Legislative History
Church Alliance, From External Meeting on 10/4/2011
Church Alliance, From External Meeting on 10/4/2011
10/04/2011
061_JohnsFrank_1094
From External Meeting on 10/4/2011
From External Meeting on 10/4/2011
09/19/2011
Re: Proposed Regulations on Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants, File Number S7-25-11
Retirement Funds, From External Meeting on 9/19/2011
Retirement Funds, From External Meeting on 9/19/2011
09/16/2011
Re: Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants (File No. S7-25-11)
Consumer Federation of America, From External Meeting on 9/16/2011
Consumer Federation of America, From External Meeting on 9/16/2011
09/16/2011
Re: Business Conduct Standards for Securities-Based Swap Dealers and Major Securities Based Swap Participants; File Number S7-25-11
Better Markets, From External Meeting on 9/16/2011
Better Markets, From External Meeting on 9/16/2011
09/15/2011
Agency exemptive authority
ABC-CIEBA, From External Meeting on 9/15/2011
ABC-CIEBA, From External Meeting on 9/15/2011
09/09/2011
The Church Alliance: A History
Church Alliance, From External Meeting on 9/9/2011
Church Alliance, From External Meeting on 9/9/2011
09/09/2011
Proposed Agenda for CFTC Meeting
Church Alliance, From External Meeting on 9/9/2011
Church Alliance, From External Meeting on 9/9/2011
09/07/2011
SEC Hearing on The State of Municipal Securities Market
Andrew Kalotay Associates, From External Meeting on 9/7/2011
Andrew Kalotay Associates, From External Meeting on 9/7/2011
08/30/2011
Re: File Number S7-25-11/ Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants with Counterparties
American Benefits Council, From External Meeting on 8/30/2011
American Benefits Council, From External Meeting on 8/30/2011
08/30/2011
Re: Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants; File Number S7-25-11; RIN 3235-AL10
BlackRock, From External Meeting on 8/30/2011
BlackRock, From External Meeting on 8/30/2011
08/30/2011
Re: Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants (File No. S7-25-11)
Consumer Federation of America / Americans for Financial Reform, From External Meeting on 8/30/2011
Consumer Federation of America / Americans for Financial Reform, From External Meeting on 8/30/2011
08/30/2011
Levin comment ltr on SEC swap dealer business conduct standards (8-29-11)_1126
From External Meeting on 8/30/2011
From External Meeting on 8/30/2011
08/29/2011
Re: Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants (File No. S7-25-11)
Consumer Federation of America / Americans for Financial Reform, From External Meeting on 8/29/2011
Consumer Federation of America / Americans for Financial Reform, From External Meeting on 8/29/2011
06/06/2011
FW: CFTC meeting regarding the business conduct standards
American Benefits Council, From External Meeting on 6/6/2011
American Benefits Council, From External Meeting on 6/6/2011
04/12/2011
SDs and MSPs Should Not be Treated as Identical Twins
BlackRock, From External Meeting on 4/12/2011
BlackRock, From External Meeting on 4/12/2011
04/08/2011
April 11 Mtg. Summary with Rabobank_752
From External Meeting on 4/8/2011
From External Meeting on 4/8/2011
04/05/2011
02/09/2011
Comment on proposed rules for Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties
Skadden Arps, From External Meeting on 2/9/2011
Skadden Arps, From External Meeting on 2/9/2011
12/09/2010
12/03/2010
10/29/2010
The Fiduciary Reference
The Committee for the Fiduciary Standard
The Committee for the Fiduciary Standard
10/22/2010
Definition of the Term ?Fiduciary?
Department of Labor
Department of Labor
10/22/2010
10/19/2010
APPLICABILITY OF BUSINESS CONDUCT STANDARDS TO ERISA PLANS
American Benefits Council
American Benefits Council
10/14/2010
Agenda for Morgan Stanley Meeting with SEC
Morgan Stanley
Morgan Stanley
10/14/2010
Morgan Stanley Agenda_173
Morgan Stanley, From External Meeting on 10/14/2010
Morgan Stanley, From External Meeting on 10/14/2010
09/29/2010
Natural Gas Supply Association
Natural Gas Supply Association
Natural Gas Supply Association
09/29/2010
NGSA CFTC Comments_09.28.2010_100
Natural Gas Supply Association (NGSA), From External Meeting on 9/29/2010
Natural Gas Supply Association (NGSA), From External Meeting on 9/29/2010
09/17/2010
09/17/2010
Comments of American Benefits Council Provided at 9-17 CFTC Meeting_25
American Benefits Council, From External Meeting on 9/17/2010
American Benefits Council, From External Meeting on 9/17/2010
09/17/2010
Agenda of 9-17 CFTC-SEC Meeting with Pension Plans_25
American Benefits Council, From External Meeting on 9/17/2010
American Benefits Council, From External Meeting on 9/17/2010
09/15/2010
Meeting Summary with Morgan Stanley_14
Morgan Stanley, From External Meeting on 9/15/2010
Morgan Stanley, From External Meeting on 9/15/2010
09/14/2010
NCFC Grain Farmer Co-op Hedging_7
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
09/14/2010
NCFC Fuel Farmer Co-op Hedging_7
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
09/14/2010
NCFC Hedging Dairy_7
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
09/14/2010
Dodd-Frank OTC Derivatives 2010_7
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
09/14/2010
NCFC Hedging Fertilizer_7
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
National Council of Farmer Cooperatives (NCFC), From External Meeting on 9/14/2010
09/08/2010
comments regarding certain business conduct standards
American Benefits Council
American Benefits Council
09/02/2010
Comments on Business Conduct Standards
Ropes & Gray LLP
Ropes & Gray LLP
09/01/2010
dmb argus_72
Argus Oil Market Regulation Summit 2010
Argus Oil Market Regulation Summit 2010
08/31/2010
Partial list of DOL individual exemptions
Groom Law Group
Groom Law Group
08/31/2010
Email from Richard Matta of Groom Law Group
Groom Law Group
Groom Law Group
08/31/2010
08/30/2010
08/30/2010
Email
Peter Shapiro
Peter Shapiro
08/30/2010
08/30/2010
08/30/2010
ERISA for Securities Professionals
Groom Law Group
Groom Law Group
08/26/2010
08/25/2010
08/17/2010
08/17/2010
08/17/2010
08/13/2010
Tennessee SWAP GuidelinesBanking Committee
Tennessee Comptroller of the Treasury
Tennessee Comptroller of the Treasury
08/12/2010
August 12 Meeting - Discussion Topics
Public Pension Groups
Public Pension Groups
08/09/2010
Title VII discussion with SEC/CFTC
Swap Financial Group
Swap Financial Group
08/09/2010
A Special Investigation of the Bethlehem Area School District, Lehigh/Northampton Counties
Americans for Financial Reform (AFR), Consumer Federation of America (CFA), AFL-CIO, AFSCME, and SEIU
Americans for Financial Reform (AFR), Consumer Federation of America (CFA), AFL-CIO, AFSCME, and SEIU
08/09/2010
Briefing for SEC/CFTC Joint Working Group
Swap Financial Group
Swap Financial Group
08/09/2010
Agenda for SEC Meeting
Americans for Financial Reform (AFR), Consumer Federation of America (CFA), AFL-CIO, AFSCME, and SEIU
Americans for Financial Reform (AFR), Consumer Federation of America (CFA), AFL-CIO, AFSCME, and SEIU
08/05/2010
08/05/2010
08/05/2010
08/05/2010
08/04/2010
National Futures Association's Business Conduct Rules
National Futures Association
National Futures Association
See Also:
