External Meetings: Phone Call with Cobank

The discussion centered on the de minimis exception from the definition of swap dealer, and whether different de minimis thresholds should apply to different types of entities.  CoBank expressed the view that farm credit system institutions should be subject to a higher de minimis threshold to create a level playing field with insured depository institutions, which are eligible for a statutory exception from the definition for swaps in connection with the origination of loans.  CoBank explained that the swaps it enters into are also in connection with the origination of loans, and it is concerned that the incremental burden of compliance with swap dealer regulations would lead it to stop offering such swaps.