Participants discussed Jackson’s use of swaps and Jackson’s concern that certain requirements under the Dodd Frank Act may reduce liquidity in the swap market.  In general, Jackson said that requirements that swaps be cleared and publicly reported may discourage dealers and swap users from entering into swaps, especially those with large notional values.  For example, Jackson is concerned that if swap clearinghouses are able to unilaterally change margin requirements, such changes at times of market stress could reduce swap availability when they are most needed.  Also, m

Russell Investment representatives discussed current industry practices concerning (1) identifying and managing conflicts of interest; and (2) selecting competent investment managers.

FXall discussed regulatory reporting obligations of SEFs and practical matters raised by the proposed rules. FXall requested greater clarity regarding the process for selection of an SDR and reporting by a SEF on behalf of SEF members.

Discussion regarding acceptance of letters of credit as initial margin; mandatory clearing of swaps; definition of "swap"; and proposed rules on governance and conflicts of interest.

Mr. Kalotay discussed industry practices regarding municipal issuers use of bonds and interest rate swaps, including the selection of swap advisors and issues regarding conflicts of interest and independence.

The Church Alliance representatives discussed the points made in its comment letter to the Commission and to the SEC on Business Conduct Standards with Counterparties.

Discussion regarding SEF routing and connectivitiy to DCOs. FXall expressed the desire for greater clarity in the proposed regulation.

The Church Alliance representatives discussed the points made in its comment letters on Business Conduct Standards with Counterparties, Definitions of Swap Dealers and Major Swap Participants, and the End-User Exception.

Meeting to discuss customer clearing documentation and timing of acceptance for clearing.

DSG representatives called on behalf of their state pension fund clients regarding the timing and approach to certification of independent representatives.
 
CFTC staff stated that the external Business Conduct Standards rules would likely be considered in fall 2011 and that staff is considering recommending a policies and procedures approach for Special Entities selection of independent representatives based on the statutory criteria, pending any future certification process that NFA or another body might develop.