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.

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.