External Meetings: Meeting with SIFMA

The external attendees discussed their views about the proposed External Business Conduct Standards rules as expressed in the SIFMA/ISDA February 17 comment letter and made some drafting suggestions.
The external attendees also raised issues regarding the July 2011 effective date of the Dodd-Frank Act amendments to the Commodity Exchange Act, especially with respect to the Business Conduct Standards provisions in §4s(h).  The external attendees commented that Commission guidance or relief may be appropriate prior to the effective date to avoid disruptions to ERISA pension plans and other Special Entities’ access to the swaps markets.