External Meetings: Meeting with Nomura

Nomura believes that, generally, the regulation of swap dealers that are active in various countries should focus on the swap dealers’ activities with counterparties that are US persons.  Clearing and data reporting requirements should apply to swaps with US persons.  The CFTC should endeavor to defer to home country regulation when non-US entities are well-regulated.  Swaps between affiliates should not be considered in determining if any of the parties to the swaps is a swap dealer.