ISDA/SIFMA/IIB SBS Comment Letters to SEC

On March 21, ISDA, the Institute of International Bankers (IIB) and the Securities Industry and Financial Markets Association (SIFMA) submitted comment letters to the Securities and Exchange Commission (SEC) on three proposed security-based swaps (SBS) rules under the Securities Exchange Act of 1934: 1. Proposed Rule 15Fh-4(c) Prohibition Against Undue Influence over Chief Compliance Officers, 2. Proposed Rule 10B-1 Position Reporting of Large Security-Based Swap Positions and 3. Proposed Rule 9J-1 Prohibition Against Fraud, Manipulation or Deception in Connection with Security-Based Swaps.

A Financial Markets Revolution

Every financial center has its own unique features, but it was particularly fitting that ISDA’s recent Annual General Meeting (AGM) was held in Boston – not only a global hub for asset management and insurance, but also a city that...