Topic: Derivatives

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Banking, Derivatives, Public Policy & Advocacy

CFTC Agricultural Advisory Committee

May 19, 2011 | Commodity Futures Trading Commission (CFTC)

As a member of the CFTC Agricultural Advisory Committee representing the American Bankers Association (ABA), Diana raised issues about the exemption for swaps entered into in connection with originating loans and the small bank clearing exemption. She also engaged in a discussion about the timing of different agency proposals on margin requirements, including mention of mixed swaps that will be subject to both CFTC and SEC jurisdiction.

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Banking, Derivatives, Public Policy & Advocacy, Securities & Capital Markets

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.

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Banking, Derivatives, Public Policy & Advocacy, Securities & Capital Markets

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.

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