External Meetings: Meeting with American Bankers Assoc. Securities Association

Mr. Berkovitz provided general information regrarding the status of various CFTC proposed rulemakings, particularly with respect to proposed rulemakings of interest to banks.  Mr. Berkovitz focused his remarks on the proposed rulemaking to define swap dealers and major swap participants, internal and external business conduct standards for swap dealers, and clearing requirements.  Questions focused on the extraterritorial application of these provisions.  Several participants expressed concern regarding the potential for regulatory arbitrage if US standards applied more stringently to US banks operating overseas than to foreign banks.