ABA wrote to the House Agriculture Committee to outline our positions on bills the Committee will be marking-up today, including ABA-supported legislation to clarify that end users would not be subject to margin requirements for un-cleared swaps (H.R. 634), to reform the swaps “push-out” requirement (H.R. 992), and to provide for a full assessment of the costs and benefits of CFTC regulations (H.R. 1003).
Regarding a bill (H.R. 677) that would exempt inter-affiliate swaps from certain regulatory requirements that the Dodd-Frank Act put in place, ABA stated support for provisions to clarify that inter-affiliate swaps should be exempt from many of the anticipated swap regulations, but urged the Committee “to remove the limitation on transactions involving swap dealers and major swap participants that are insured depository institutions.”
In addition, ABA provided comments on a discussion draft of legislation to require the CFTC and SEC to jointly adopt rules setting forth the application of Title VII to cross-border transactions.
Read the letter.