External Meetings: Definitions Meeting w/ Financial Services Roundtable

The meeting discussed points made by the Financial Services Roundtable in a comment letter submitted on October 17, 2011, primarily regarding the exclusion in the definition of swap dealer for swaps entered into by insured depository institutions in connection with the origination of loans.  The Roundtable is particularly concerned by any requirement that such swaps be entered into contemporaneously with the origination of a loan.  Also, they believe any swap closely linked to the loan should be covered by the exclusion (rather than limiting the exclusion to swaps related to the financial terms of the loan).  The Roundtable also pointed out that the costs to an insured depository institution from being designated as a swap dealer are potentially more significant as a result of the requirement that such institutions not engage in certain proprietary trading.