Topic: Banking

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

February 22, 2011 | American Bankers Association (ABA)

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.

The Financial Crisis of 2007-2009 Causes and Contributing Circumstances

January 12, 2010 | American Bar Association

Contributing author of the report prepared by the ABA Business Law Section Banking Law Committee (BLC) Task Force on the Causes of the Financial Crisis. This BLC Task Force was formed as a subgroup of the Task Force on Financial Regulatory Restructuring, which was appointed by the BLC to analyze financial regulatory and systemic issues that may have caused and contributed to the 2007-2009 financial crisis.