The Securities Industry and Financial Markets Association and the International Swaps and Derivatives Association have raised concerns regarding proposals on business conduct standards for swap dealers and major swap participants proposed by the U.S. Commodity Futures Trading Commission. In a letter to the CFTC, the SIFMA and ISDA stated, among other things, that the “overly broad proposal could effectively preclude participation in the over-the-counter swap markets by pension plans, municipalities and other special entities.”
