External Meetings: Meeting with the Coalition of Derivatives End-users

Commissioner Chilton met with some representatives of the Coalition of Derivatives End-users (hereafter “The Coalition”).  The conversation centered around three main issues: (1) Inter-Affiliate Swaps and Reporting Issues (inter-affiliate swap reporting, timing); (2) Margin; and (3) Cross Border issues.~~~As for the Inter-Affiliate Swaps and Reporting Issues, the Coalition reemphasized issues they had formally raised in their Comment Letter.  Specifically, the Coalition reemphasized its position that placing stringent regulations, including reporting requirements, on affiliate-to-affiliate exchanges significantly burden the end-users, who were not the main focus of Dodd-Frank.  The Commissioner noted that he was aware of their concerns.  The Commissioner also noted that he could not discuss the issue in any detail given that the Commission is in the post-comment period.  ~~~As for the discussion on Margins, the coalition reemphasized issues they had formally raised in their Comment Letter.  Specifically, they supported the CFTC’s proposal to not require margin for end-user swaps, but were concerned that prudential regulators in the U.S. and elsewhere may press to require margin for all uncleared swaps.  The Commissioner noted their concerns and emphasized that, because the Commission is in a post-comment period, he could not speak on the issue.~~~As for Cross Border issues, the Coalition emphasized that the end-users expressed frustration that the recent Commission releases on ~Cross-Border issues did not seem to contemplate end-users.”