On July 12, 2012, the CFTC published a proposal to temporarily relieve non-U.S. swap dealers from compliance with certain swap regulations.  On August 13, 2012, SDUUK issued a comment letter that concludes the CFTC’s proposal is inadequate in a number of ways.

SDUUK’s comment letter explains that the goal of temporary exemptive relief is to ameliorate the uncertainties faced by swap dealers.  The comment letter then offers three objectives the CFTC must achieve to accomplish this underlying goal.  

First, the CFTC must provide a complete exemption from rules that are still subject to comment.  Second, relief must treat swap dealers equally to avoid creating an unleveled playing field.  Third, relief must provide sufficient time to allow orderly transition to the new regulatory regimes domestically and abroad.

Related Documents:
Proposed Exemptive Order