The ABA petition seeks exemptive relief and interim no-action relief for bank and savings and loan holding companies of the banks and savings and loans that are eligible for the end-user clearing exception. Specifically, the petition seeks to treat the holding company the same as the end-user banks and also be eligible for the clearing exception. The CFTC granted no-action relief on January 8, 2016.

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.