External Meetings: Meeting with Institute of International Bankers

IIB presented general comment on cross-border issues, the aggregation of dealing swaps, and the treatment of legacy portfolios.  IIB commented that compliance with entity-level Dodd-Frank rules would present practical issues that cannot be resolved in three months.  IIB also commented that their members were having difficulties implementing the broad proposed definition of U.S. person, particularly as they relate to the “principal place of business” and the foreign funds prongs.  IIB also requested clarification on the aggregation of dealing swaps as three different methods of aggregation have been presented in Commission or staff actions, i.e., in the swap dealer final rule, in the cross-border proposal, and the cross-border final exemptive order.  IIB also urged action on an October request for clarification on the treatment of legacy portfolios in the context of SD registration requirements.