External Meetings: Meeting with Morgan Stanley

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.
I. Registration

II. Definitions

III. Business Conduct Standards w/ Counterparties

IV. Business Conduct Standards – Internal

V. Capital & Margin

CFTC Staff
Gary Gensler

Gary Barnett

Dan Berkovitz

Dhaval Patel

Jeff Burns

Carl Kennedy

David Aron

Tim Karpoff

Sarah Josephson
Soo-Mi Lee

William McCoy

Anthony Cicia

Michael Stein
Morgan Stanley