Telephone Call regarding Customer Protection Rule.

Discussion of Segregation Acknowledgement Letters Requirement in the Rulemaking Enhancing Protections Afforded Customers and Customer Funds Held by Futures Commission Merchants and Derivatives Clearing Organizations.


Meeting held via VTC in Chicago, DC, NY and via telephone.

IIB presented general comment on cross-border issues, the aggregation of dealing swaps, and the treatment of legacy portfolios.  IIB commented that compliance with entity-level Dodd-Frank rules would present practical issues that cannot be resolved in three months.  IIB also commented that their members were having difficulties implementing the broad proposed definition of U.S.

Discussion of when a swap is with a foreign branch as opposed to a home office.

Discussion of procedures for cross-border substituted compliance and international rule harmonization, focusing on areas such as capital requirements, reporting and risk management policies and procdures.  Also discussed requirements potentially applicable to foreign exchange transactions.

Discussion of reporting requirements - recent no-action relief for certain swaps between affiliates and reporting of cross-border swaps.

Participants discussed SEF registration and execution methods.