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External Meetings: Meeting with Morgan Stanley
III. Business Conduct Standards w/ Counterparties
IV. Business Conduct Standards – Internal
V. Capital & Margin
Representatives from Morgan Stanley discussed the extraterritorial application of the Dodd-Frank Act (Act) requirements for swap dealers. Specifically, the representatives asked the Commission to: (1) issue guidance on the extraterritorial reach of the Act in order to provide clarity to market participants; (2) when appropriate, defer to comparable foreign regulatory regimes; (3) harmonize the Commission’s swap rules with the security-based swap rules of the Securities and Exchange Commission; (4) through a rulemaking or interpretative guidance, address the application of transaction-level requirements on inter-affiliate transactions; and (5) implement the swap rules in a manner that does not create opportunities for regulatory arbitrage.