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Comments on Concept Release: Definitions Contained in Title VII of Dodd-Frank Wall Street Reform and Consumer Protection Act
[Release No. 34-62717; File No. S7-16-10]
See also: Comments on Proposed Rule: Further Definition of "Swap Dealer," "Security-Based Swap Dealer," "Major Swap Participant," "Major Security-Based Swap Participant" and "Eligible Contract Participant"; File No. S7-39-10 and
Comments on Dodd-Frank Title VII, Security-Based Swap Dealers and Major Security-Based Swap Participants
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(Click here for meetings with SEC officials)
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Comments have been received from individuals and entities using the following Letter Type A: 1566 |
Sep. 12, 2011 | Christopher A. Klem, Ropes & Gray LLP |
Sep. 8, 2011 | ABA Securities Association, American Council of Life Insurers, Financial Services Roundtable, Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association |
May 31, 2011 | Futures Industry Association, The Financial Services Roundtable, Institute of International Bankers, Insured Retirement Institute, International Swaps and Derivatives Association, Securities Industry and Financial Markets Association, and U.S. Chamber of Commerce |
May 4, 2011 | Financial Services Forum, Futures Industry Association, International Swaps and Derivatives Association, and Securities Industry and Financial Markets Association |
Apr. 14, 2011 | "Swap Dealers and Major Swap Participants
Should Not be Treated as Identical Twins" submitted by Blackrock |
Apr. 5, 2011 | John F. Gandolfo, Acting Vice President & Treasurer, The World Bank |
Mar. 24, 2011 | Richard H. Baker, President & Chief Executive Officer, Managed Funds Association |
Mar. 18, 2011 | Gunter Pleines, Head of Banking Department and Diego Devos, General Counsel, Bank for International Settlements |
Mar. 1, 2011 | Elliot Ganz, General Counsel, The Loan Syndications & Trading Association |
Feb. 23, 2011 | Clare Dawson, Managing Director, Loan Market Association |
Feb. 22, 2011 | National Corn Growers Association and Natural Gas Supply Association |
Feb. 22, 2011 | Lee Ming Chua, General Counsel, Government of Singapore Investment Corporation Pte Ltd, Singapore |
Feb. 18, 2011 | Stacy C. Kymes, Executive Vice President, BOK Financial |
Feb. 18, 2011 | CFTC Phase-in Implementation Discussion |
Feb. 3, 2011 | Gerald Donini, Barclays Capital Inc. |
Jan. 25, 2011 | R. Bram Smith, Executive Direcor, The Loan Syndications and Trading Association, New York, New York |
Dec. 14, 2010 | James Michener, General Counsel, Assured Guaranty Ltd. |
Dec. 5, 2010 | Chris Barnard, Germany |
Nov. 24, 2010 | Timothy W. Cameron, Esq., Managing Director, Asset Management Group, Securities Industry and Financial Markets Association |
Nov. 10, 2010 | Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy and Advocacy, Securities Industry and Financial Markets Association |
Nov. 9, 2010 | Comment Letter from the National Association of Insurance Commissioners regarding a September 29, 2010 meeting with Securities and Exchange Commission and the Commodity Futures Trading Commission |
Nov. 5, 2010 | Americans for Financial Reform |
Nov. 4, 2010 | Dexter Senft, Managing Director, Morgan Stanley |
Nov. 2, 2010 | James P. Hoffa, General President, and C. Thomas Keegel, General Secretary-Treasurer, The International Brotherhood of Teamsters |
Nov. 1, 2010 | James Hill, Managing Director, Morgan Stanley |
Oct. 27, 2010 | Kenneth E. Bentsen, Jr., Executive Vice President, Public Policy and Advocacy, SIFMA |
Sep. 24, 2010 | Patrick J. Nugent, Executive Director, Texas Pipeline Association |
Sep. 24, 2010 | Richard A. Miller, Esq., Vice President and Corporate Counsel, Financial Management Law, The Prudential Insurance Company of America |
Sep. 24, 2010 | Andrew Baker, Chief Executive Officer, The Alternative Investment Management Association |
Sep. 24, 2010 | Convexity Capital Management LP |
Sep. 23, 2010 | Stuart J. Kaswell, Executive Vice President, Managing Director & General Counsel, Managed Funds Association |
Sep. 21, 2010 | Dan Shackelford and Jonathan D. Siegel, T. Rowe Price Associates, Inc. |
Sep. 21, 2010 | Edward J. Rosen, Cleary Gottlieb Steen & Hamilton LLP |
Sep. 20, 2010 | Thaddeus Huettemann, Jeffrey C. Fort, and Jeremy D. Weinstein; Environmental Markets Association |
Sep. 20, 2010 | Carl B. Wilkerson, Vice President & Chief Counsel, Securities & Litigation, American Council of Life Insurers |
Sep. 20, 2010 | Coalition for Derivatives End-Users |
Sep. 20, 2010 | Timothy W. Cameron, Managing Director, Asset Management Group, Securities Industry and Financial Markets Association |
Sep. 20, 2010 | Jennifer J. Kalb, Associate General Counsel, Metropolitan Life Insurance Company, Morristown, New Jersey |
Sep. 20, 2010 | Ernest C. Goodrich, Jr. and Marcelo Riffaud, Deutsche Bank AG |
Sep. 20, 2010 | Richard M. Whiting, Financial Services Roundtable |
Sep. 20, 2010 | Kenneth A. Kopelman, Bingham McCutchen LLP, on behalf of Union Bank, N.A., Regions Bank and Fifth Third Bancorp |
Sep. 20, 2010 | Eric Dennison, Stephanie Miller, and Bill Hellinghausen, EDF Trading North America, LLC |
Sep. 20, 2010 | Edward W. Gallagher, President, Dairy Risk Management Services, Dairy Farmers of America, Inc. |
Sep. 20, 2010 | Lisa M. Ledbetter, Vice President and Deputy General Counsel, Freddie Mac |
Sep. 20, 2010 | Richard F. McMahon, Jr., Executive Director, Edison Electric Institute |
Sep. 20, 2010 | American Benefits Council and the Committee on the Investment of Employee Benefit Assets |
Sep. 20, 2010 | Anne Simpson, Senior Portfolio Manager, Global Equity, California Public Employees' Retirement System |
Sep. 20, 2010 | Anthony M. Mansfield and Jonathan H. Flynn, McDermott Will & Emery LLP, on behalf of the Hess Corporation |
Sep. 20, 2010 | Karrie McMillan, General Counsel, Investment Company Institute |
Sep. 20, 2010 | Gus Sauter, Chief Investment Officer, Vanguard |
Sep. 20, 2010 | Joanne T. Medero, Managing Director, BlackRock |
Sep. 20, 2010 | William J. Brodsky, Chairman and Chief Executive Officer, Chicago Board Options Exchange, Incorporated |
Sep. 20, 2010 | Steve Martinie, Assistant General Counsel
and Assistant Secretary, Northwestern Mutual Life Insurance Company |
Sep. 20, 2010 | White & Case LLP |
Sep. 20, 2010 | Jane L. Cline, President, and Therese M. Vaughan, Ph.D., Chief Executive Officer, National Association of Insurance Commissioners |
Sep. 20, 2010 | Stephen H. McElhennon, Vice President & Deputy General Counsel, Fannie Mae |
Sep. 20, 2010 | Kathleen L. Barrón, Esq., Vice President, Federal Regulatory Affairs and Policy, Noel Trask, Esq., Lead Counsel, Exelon Power Team, Exelon Corporation, and David M. Perlman, Bracewell & Giuliani LLP |
Sep. 20, 2010 | David Carroll, Senior Counsel, American Express Company |
Sep. 20, 2010 | Patrick Kelly, Policy Advisor, American Petroleum Institute |
Sep. 20, 2010 | David M. Perlman, on behalf of the Coalition of Physical Energy Companies |
Sep. 20, 2010 | Jay Brown, Chief Executive Officer, MBIA Inc. |
Sep. 20, 2010 | John M. Damgard, President, Futures Industry Association |
Sep. 20, 2010 | H. Steven Walton, Frederic Dorwart, Lawyers, on behalf of Bank of Oklahoma National Association |
Sep. 20, 2010 | Not-For-Profit Energy End User Coalition |
Sep. 20, 2010 | Jane Hamblen, State of Wisconsin Investment Board |
Sep. 20, 2010 | Richard Ostrander, Managing Director and Counsel, Morgan Stanley |
Sep. 20, 2010 | American Seniors Housing Association, Building Owners and Managers Association International, International Council of Shopping Centers, NAIOP, the Commercial Real Estate Development Association, National Apartment Association, National Association of Real Estate Investment Trusts, National Multi Housing Council, and The Real Estate Roundtable |
Sep. 20, 2010 | Robert J. Duke, Director of Underwriting/Assistant Counsel, The Surety & Fidelity Association of America |
Sep. 20, 2010 | Thomas W. Jasper, Chief Executive Officer, Primus Guaranty Ltd. and Gene Park, Chief Executive Officer, Quadrant Structured Investment Advisers, LLC |
Sep. 20, 2010 | Stephen Linehan, Executive Vice President and Treasurer, Capital One Financial Corporation |
Sep. 20, 2010 | Thomas Book, Member of the Executive Board, and Vassilis Vergotis, Executive Vice President, Eurex and Eurex Clearing AG |
Sep. 20, 2010 | Carolyn Walsh, Vice President and Senior Counsel Center for Securities, Trust & Investments, American Bankers Association |
Sep. 20, 2010 | J. Stephen Zielezienski, Senior Vice President & General Counsel, American Insurance Association |
Sep. 20, 2010 | Robert Pickel, Executive Vice Chairman, International Swaps and Derivatives Association, Inc. |
Sep. 20, 2010 | Lee Ming Chua, General Counsel, Government of Singapore Investment Corporation |
Sep. 20, 2010 | The Swaps & Derivatives Market Association |
Sep. 20, 2010 | Franklin W. Nutter, President, Reinsurance Association of America |
Sep. 20, 2010 | Andrew Baker, Chief Executive Officer, The Alternative Investment Management Association |
Sep. 17, 2010 | William E. Balson, Director, OTC Online, LLC and Dr. Gordon C. Rausser, Robert Gordon Sproul Distinguished Professor, University of California, Berkeley |
Sep. 17, 2010 | James M. Olsen, Senior Director Accounting and Investment Policy, Property Casualty Insurers Association of America |
Sep. 17, 2010 | Leo Pylypec, Managing Director, FTN Financial Capital Markets |
Sep. 15, 2010 | Joel G. Newman, President & CEO, American Feed Industry Association |
Sep. 13, 2010 | James M. Michener, General Counsel, Assured Guaranty Corp. | Sep. 9, 2010 | Keith M. Sappenfield, II, Director, US Regulatory Affairs, Midstream, Marketing and Fundamentals, Encana Marketing (USA) Inc. |
Sep. 5, 2010 | Andrew Reyburn, Michigan |
Sep. 2, 2010 | Christopher Klem, Ropes & Gray LLP, Boston, MA |
Jul. 30, 2010 | Charles W. Wilcoxson |
Jul. 28, 2010 | Robin McLeish, Virginia Beach, Virginia |
Feb. 3, 2010 | Coalition for Derivatives End-Users |
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Meetings with SEC Officials
(Click here for submitted comments from the public)
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Aug. 10, 2012 | Memorandum from the Division of Trading and Markets regarding an August 6, 2012, meeting with representatives from the Association of Financial Guaranty Insurers |
Jun. 15, 2011 | Memorandum from the Division of Trading and Markets regarding a June 15, 2011 meeting with representatives of the Investment Company Institute |
May 20, 2011 | Memorandum from the Division of Trading and Markets regarding a May 20, 2011, meeting with representatives from Morgan Stanley |
May 20, 2011 | Memorandum from the Division of Trading and Markets regarding a May 15, 2011, meeting with representatives from Siemens Corporation |
May 13, 2011 | Memorandum from the Division of Trading and Markets regarding a May 13, 2011, meeting with a representative from Kalorama Partners, LLC |
May 13, 2011 | Memorandum from the Division of Trading and Markets regarding a May 12, 2011, meeting with representatives from Barclays Capital |
May 13, 2011 | Memorandum from the Division of Trading and Markets regarding an April 27, 2011, meeting with representatives from the Securities Industry and Financial Markets Association (SIFMA) |
May 11, 2011 | Memorandum from the Division of Trading and Markets regarding a May 11, 2011, telephonic meeting with Robert Colby of Davis Polk & Wardwell LLP |
May 11, 2011 | Memorandum from the Division of Trading and Markets regarding a May 9, 2011, telephonic meeting with representatives the Capital Steering Committee of the Securities Industry and Financial Markets Association (SIFMA) |
May 4, 2011 | Memorandum from the Division of Trading and Markets regarding a May 4, 2011, meeting with representatives of the Institute of International Bankers (IIB) |
Mar. 30, 2011 | Memorandum from the Division of Trading and Markets regarding a March 30, 2011, meeting with representatives of Nomura Securities International, Inc. |
Mar. 28, 2011 | Memorandum from the Division of Trading and Markets regarding a March 28, 2011 telephonic meeting with representatives of Cleary Gottlieb Steen & Hamilton LLP |
Mar. 28, 2011 | Memorandum from the Division of Trading and Markets regarding a March 28, 2011 telephonic meeting with representatives of International Swaps and Derivatives Association, Inc. |
Mar. 28, 2011 | Memorandum from the Division of Trading and Markets regarding a March 24, 2011 telephonic meeting with Edward Rosen |
Mar. 25, 2011 | Memorandum from the Division of Trading and Markets regarding a March 25, 2011, meeting with representatives of Goldman Sachs |
Mar. 23, 2011 | Memorandum from the Division of Trading and Markets regarding a March 18, 2011 telephonic meeting with representatives of Markit |
Mar. 21, 2011 | Memorandum from the Division of Trading and Markets regarding a March 21, 2011 telephonic meeting with representatives of International Swaps and Derivatives Association, Inc. |
Mar. 9, 2010 | Memorandum from the Division of Trading and Markets regarding a March 9, 2011 meeting with a representative of the Goldman Sachs Group, Inc. |
Mar. 9, 2011 | Memorandum from the Division of Trading and Markets regarding a March 9, 2011, meeting with representatives from and members of the Managed Funds Association (MFA) |
Mar. 3, 2011 | Memorandum from the Division of Trading and Markets regarding a March 3, 2011, meeting with representatives of the Institute of International Bankers (IIB) |
Mar. 1, 2011 | Memorandum from the Division of Trading and Markets regarding a March 1, 2011, meeting with representatives of Nomura Holding America Inc. and Nomura Securities International, Inc |
Feb. 23, 2011 | Memorandum from the Division of Trading and Markets regarding a February 23, 2011 meeting with representatives of the Property Casualty Insurers Association of America |
Feb. 22, 2011 | Memorandum from the Division of Trading and Markets regarding a telephonic meeting with representatives of the Capital Steering Committee of the Securities Industry and Financial Markets Association (SIFMA) |
Feb. 17, 2011 | Memorandum from the Division of Trading and Markets regarding a February 17, 2011 meeting with representatives of the Bank for International Settlements |
Feb. 14, 2011 | Memorandum from the Division of Trading and Markets regarding a February 14, 2011 meeting with representatives of Weil, Gotshal & Manges LLP |
Feb. 10, 2011 | Memorandum from the Division of Trading and Markets regarding a January 27, 2011, meeting of the OTC Derivatives Supervisors Group (ODSG) with major participants in the OTC derivatives market |
Feb. 10, 2011 | Memorandum from the Division of Trading and Markets regarding a January 27, 2011, meeting of the OTC Derivatives Supervisors Group (ODSG) with major participants in the OTC derivatives market |
Feb. 4, 2011 | Memorandum from the Division of Trading and Markets regarding a February 4, 2011, telephonic meeting with Ed Rosen of Cleary Gottlieb Steen & Hamilton LLP |
Jan. 31, 2011 | Memorandum from the Office of Commissioner Walter regarding a January 31, 2011, meeting with representatives of Nomura Holding America Inc. |
Nov. 17, 2010 | Memorandum from the Division of Trading and Markets regarding a November 17, 2010 meeting with representatives of Property Casualty Association of America |
Nov. 16, 2010 | Memorandum regarding an October 14, 2010 meeting with representatives of Depository Trust Clearing Corporation |
Nov. 12, 2010 | Memorandum from the Office of Commissioner Walter regarding a November 12, 2010 meeting with representatives of the International Swaps and Derivatives Association |
Nov. 12, 2010 | Memorandum from the Division of Trading and Markets regarding a November 12, 2010 meeting with representatives of MetLife |
Nov. 12, 2010 | Memorandum from the Division of Trading and Markets regarding a November 10, 2010 meeting with representatives of ERISA-Regulated Pension Plans |
Nov. 8, 2010 | Memorandum from the Division of Trading and Markets regarding a November 8, 2010 meeting with representatives of the American Council of Life Insurers |
Nov. 4, 2010 | Memorandum from the Division of Trading and Markets regarding a November 4, 2010 meeting with representatives of the Credit Derivatives Product Companies |
Nov. 4, 2010 | Memorandum from the Division of Trading and Markets regarding a November 4, 2010 meeting with representatives of the Association of Institutional Investors |
Oct. 28, 2010 | Memorandum from the Division of Trading and Markets re: Meeting with the Capital Steering Committee of the Securities Industry and Financial Markets Association |
Oct. 28, 2010 | Memorandum from the Division of Trading and Markets re: Phone Conference with Representatives of the Depository Trust and Clearing Corporation |
Oct. 27, 2010 | Memorandum from the Division of Trading and Markets regarding an October 27, 2010 phone conference with representatives of Chatham Financial |
Oct. 14, 2010 | Memorandum from the Office of Commissioner Troy A. Paredes regarding a October 14, 2010 meeting with representatives of UBS |
Oct. 13, 2010 | Memorandum from the Division of Trading and Markets regarding an October 13, 2010 meeting with representatives of various Buy-Side Firms |
Oct. 8, 2010 | Memorandum from the Division of Trading and Markets regarding an October 8, 2010 meeting with representatives of Bank of America |
Oct. 8, 2010 | Memorandum from the Office of the Chairman regarding an October 6, 2010, meeting with representatives of the Financial Services Forum |
Oct. 8, 2010 | Memorandum from the Office of the Chairman regarding an October 1, 2010, meeting with representatives of the Financial Services Roundtable |
Oct. 6, 2010 | Memorandum from the Office of Commissioner Walter regarding an October 6, 2010 meeting with representatives of PIMCO |
Oct. 5, 2010 | Memorandum from the Office of the Chairman regarding an October 5, 2010 meeting with representatives of JP Morgan |
Oct. 5, 2010 | Memorandum from the Division of Trading and Markets regarding an October 4, 2010 meeting with representatives of the Association of Institutional Investors |
Oct. 4, 2010 | Memorandum from the Division of Trading and Markets regarding an October 4, 2010 meeting with Morgan Stanley |
Sep. 29, 2010 | Memorandum from the Division of Trading and Markets regarding a September 29, 2010 meeting with representatives of the National Association of Insurance Commissioners |
Sep. 28, 2010 | Memorandum from the Division of Trading and Markets regarding a September 28, 2010, meeting with representatives of the Coalition for Derivatives End Users |
Sep. 23, 2010 | Memorandum from the Division of Trading and Markets regarding a September 23, 2010, meeting with representatives of Javelin Capital Markets, LLC |
Sep. 23, 2010 | Memorandum from the Division of Trading and Markets regarding a September 23, 2010, meeting with representatives of the Pan-Canadian Investors Committee for Third-Party Structured Asset-Backed Commercial Paper |
Sep. 23, 2010 | Memorandum from the Division of Trading and Markets regarding a September 21, 2010 meeting with the Financial Services Roundtable |
Sep. 22, 2010 | Memorandum from the Division of Trading and Markets re: U.S. Chamber of Commerce, Center for Capital Markets Competitiveness event on "Over the Counter (OTC) Derivatives Reform: Preparing for a Changing Marketplace." |
Sep. 22, 2010 | Memorandum from the Division of Trading and Markets regarding an September 22, 2010 meeting with representatives of Assured Guaranty |
Sep. 20, 2010 | Memorandum from the Division of Trading and Markets regarding a September 20, 2010 meeting with representatives of Goldman Sachs |
Sep. 20, 2010 | Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting with the CFTC and representatives from certain pension plans |
Sep. 20, 2010 | Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting with certain industry representatives |
Sep. 17, 2010 | Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting (p.m.) with representatives of Morgan Stanley |
Sep. 17, 2010 | Memorandum from the Division of Trading and Markets regarding a September 17, 2010 meeting (a.m.) with representatives of Morgan Stanley |
Sep. 15, 2010 | Memorandum from the Division of Trading and Markets regarding an October 13, 2010 meeting with representatives of the Not-For-Profit Energy End User Coalition |
Sep. 15, 2010 | Memorandum from the Office of Commissioner Paredes regarding a September 8, 2010, meeting with representatives of Credit Suisse |
Sep. 15, 2010 | Memorandum from the Office of Commissioner Troy A. Paredes regarding an August 31, 2010 meeting with representatives of the Managed Funds Association |
Sep. 10, 2010 | Memorandum from the Division of Trading and Markets regarding a September 9, 2010 meeting with representatives of the Alternative Investment Management Association (AIMA) |
Sep. 9, 2010 | Memorandum from the Office of Commissioner Aguilar regarding a September 8, 2010 meeting with representatives from the Alternative Investment Management Association |
Sep. 9, 2010 | Memorandum from the Office of Commissioner Walter regarding a September 8, 2010 meeting with representatives from the Alternative Investment Management Association |
Sep. 7, 2010 | Memorandum from the Division of Trading and Markets regarding a September 2, 2010 meeting with representatives of Assured Guaranty |
Sep. 2, 2010 | Memorandum from the Division of Trading and Markets regarding an August 25, 2010 meeting with representatives of MarkitSERV |
Sep. 1, 2010 | Memorandum from the Division of Trading and Markets regarding a September 1, 2010 meeting with representatives from the Conference of State Bank Supervisors ("CSBS"), the National Association of Insurance Commissioners ("NAIC"), and the North American Securities Administrators Association ("NASAA")" |
Sep. 1, 2010 | Memorandum from the Division of Trading and Markets regarding a September 1, 2010 teleconference with representatives of Goldman, Sachs & Co. and Goldman Sachs Execution & Clearing LLC |
Sep. 1, 2010 | Memorandum from the Office of Commissioner Walter regarding an August 31, 2010 meeting with representatives of the Managed Funds Association |
Aug. 31, 2010 | Memorandum from the Division of Trading and Markets regarding an August 31, 2010 meeting with representatives of the Managed Funds Association |
Aug. 30, 2010 | Memorandum from the Division of Trading and Markets regarding an August 27, 2010 meeting with representatives of Americans for Financial Reform, et al. |
Aug. 26, 2010 | Memorandum from the Division of Trading and Markets regarding an August 26, 2010 meeting with representatives of the International Swaps and Derivatives Association (ISDA) |
Aug. 25, 2010 | Memorandum from the Division of Trading and Markets regarding an August 25, 2010 meeting with representatives of the Securities Industry and Financial Markets Association (SIFMA), et al. |
Aug. 25, 2010 | Memorandum from the Office of International Affairs regarding an August 25, 2010 meeting with a representative of the Institute of International Finance |
Aug. 24, 2010 | Memorandum from the Office of International Affairs regarding an August 16, 2010 meeting with representatives of the Government of Singapore Investment Corporation |
Aug. 24, 2010 | Memorandum from the Division of Trading and Markets regarding an August 24, 2010 meeting with representatives of Trumarx Data Partners |
Aug. 24, 2010 | Memorandum from the Division of Trading and Markets regarding an August 23, 2010 meeting with representatives of the National Association of College and University Business Officers (NACUBO) |
Aug. 23, 2010 | Memorandum from the Division of Trading and Markets regarding an August 23, 2010 meeting with representatives of D.E. Shaw |
Aug. 17, 2010 | Memorandum from the Division of Trading and Markets regarding an August 12, 2010 meeting with representatives of the dealer industry |
Aug. 13, 2010 | Memorandum from the Office of Commissioner Troy A. Paredes regarding an August 13, 2010 meeting with representatives from The Cypress Group and Koch Companies Public Sector, LLC |
Aug. 10, 2010 | Memorandum from the Division of Trading and Markets regarding an August 9, 2010 meeting with representatives of Americans for Financial Reform, et al. |
Aug. 3, 2010 | Memorandum from the Division of Trading and Markets regarding an August 3, 2010 meeting with representatives of the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association |
http://www.sec.gov/comments/s7-16-10/s71610.shtml
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