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.
Learn more: Comment Letter on Proposed Exemption for Cooperatives