External Meetings: CFTC/SEC consultation with Swap Financial Group

Consultation held at the SEC's Washington, DC office. The participants reviewed the statutory language regarding business conduct, including ?4s(h) and ?4c(a)(7) of the Commodity Exchange Act and ?15F(h) of the Securities Exchange Act of 1934. The participants also discussed the role of a swap advisor to particular end users that may be designated as Special Entities under the Dodd-Frank Act. In addition, the participants discussed common concerns and problems that Special Entities have historically had in the OTC derivatives marketplace.