External Meetings: Meeting with BG Americas

Participants discussed issues related to the swap dealer and major swap participant definitions.  In particular BG Americas takes the view that the swap dealer definition is too broad, and that it would be helpful if the Commissions specified what activities do not constitute swap dealing.  For the de minimis exemption, BG Americas recommended setting a higher notional amount at first, that could modified in light of data received about the markets.  BG Americas also expressed concern with footnote 128 of the proposing release (in connection with the major swap participant definition), which it believes too broadly describes what does not constitute hedging or mitigating commercial risk.  Participants also discussed the forward contract exclusion from the swap definition.