External Meetings: Proprietary Trading Firms Meeting

Meeting participants discussed application of swap dealer requirements to proprietary trading firms such as DRW, Chicago Trading Company and Infinium (the "Firms"). The firms said that treating cleared and uncleared swaps in the same way to determine if a person is a swap dealer will have an adverse effect on liquidity and transparency by discouraging the use of cleared swaps. The Firms said that application of the swap dealer capital requirements (along with other swap dealer requirements, such as the need for a chief compliance officer) to smaller trading firms would discourage innovation and competition in the swap markets.