The ABA provided additional comments to the CFTC and SEC about how end-user banks with limited swaps activities and use swaps solely to hedge or mitigate risk would be affected if one of their counterparties ceased conducting business. The letter describes existing bank risk management practices and comprehensive regulation, including legal lending limits. The CFTC final rule provides a clearing exemption for banks and savings associations with $10 billion or less in total assets.

The IBFed includes representatives from bank trade associations in more than a dozen countries and the European Banking Federation. Diana gave a formal presentation to the Financial Markets Working Group about the changes in capital markets regulation as a result of the Dodd-Frank Act. Her remarks focused on the newly created Financial Stability Oversight Council (FSOC), new regulatory framework for the swaps market, Volcker Rule, and securitization reform for asset-backed securities.