Comment Letter on Further Definition of “Swap Dealer,” “Security-Based Swap Dealer,” “Major Swap Participant,” “Major Security-Based Swap Participant” and “Eligible Contract Participant”

The ABA urged the CFTC not to extend the Dodd-Frank Act swap dealer exemption for swaps entered into in connection with originating loans to the federal Farm Credit System (FCS). The statutory exemption is available only to insured depository institutions as defined in the Federal Deposit Insurance Act, which does not include the FCS. The CFTC limited the exemption to banks and savings associations.

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ABA Comment Letter

Final Rule on Swap Dealer Definition