External Meetings: Meeting with JP Morgan Chase & Co.

Representatives from JPMorgan Chase & Co. 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) permit the registration and regulation of foreign bank branches as swap dealers; (3) when appropriate, defer to comparable foreign regulatory regimes; (4) implement the swap rules in a manner that does not create opportunities for regulatory arbitrage; and (5) treat the margin requirement as a transaction-level requirement.
II. Definitions

I. Registration

III. Business Conduct Standards w/ Counterparties

IV. Business Conduct Standards – Internal

V. Capital & Margin

CFTC Staff
Gary Barnett

Carl Kennedy
Jeremy Barnum

Don Thompson

Thomas Koonce
JP Morgan Chase & Co.