Comment Letter on End-User Exception to Mandatory Clearing of Swaps and Security-Based Swaps

The Dodd-Frank Act directs the CFTC and SEC to consider an exception from clearing requirements for banks and savings associations with $10 billion or less in total assets. The ABA urged the CFTC and SEC to grant the exception to small banks and savings associations whose swaps constitute a truly de minimis amount of the market. The final CFTC rule granted an exception.

Learn more:

ABA Comment Letter

CFTC Final Rule