As a member of the CFTC Agricultural Advisory Committee representing the American Bankers Association (ABA), Diana emphasized that the ABA represents banks of all sizes including some that might only engage in swaps once every five years. She also expressed concerns about the proposed clearing exemption for cooperatives, including Farm Credit that has a $26 billion swaps portfolio. In addition, she engaged in discussion about bridge technology and data security.

As a member of the CFTC Agricultural Advisory Committee representing the American Bankers Association (ABA), Diana emphasized that the ABA represents banks of all sizes including some that might only engage in swaps once every five years. She also expressed concerns about the proposed clearing exemption for cooperatives, including Farm Credit that has a $26 billion swaps portfolio. In addition, she engaged in discussion about bridge technology and data security.

The ABA strenuously opposes the clearing exemption for certain swaps entered into by cooperatives. The CFTC has no policy justification for adopting the exemption, which grants financial institutions that are cooperatives a broader clearing exemption than banks. The exemption is arbitrary and capricious and creates competitive harm to banks while providing additional benefits to cooperatives, including a credit union with nearly $50 billion in assets and a Farm Credit bank with over $90 billion in assets.