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Futures and Derivatives Committee

The Futures and Derivatives Committee seeks to address all issues impacting the futures and derivatives markets and industry participants. The Committee is very active in commenting on proposals by the Commodity Futures Trading Commission, National Futures Association and Securities and Exchange Commission in matters related to the futures and derivatives industry. The Committee has especially been active in commenting during the past year following the adoption of the Dodd-Frank Wall Street Reform Consumer Protection Act.


Recent Reports


Letter to the National Futures Association (NFA) commenting on the NFA’s authority to impose a capital requirement on its commodity pool operator and commodity trading advisor members (March 2014) ( PDF ) 
Subject area: Commodity Pool Operator/Commodity Trading Advisor

Letter to the SEC commenting on proposed Regulation SCI and proposed Rules 13n-6 and 822 in the context of their possible application to security-based swap data repositories (SB SDR’s) and security-based swap execution facilities (SB SEF’s) (July 2013)  (PDF)

Letter to the Commodity Futures Trading Commission and Securities and Exchange Commission commenting on the use of the term “notional amount” in recent regulation and the issues arising in the calculation of “notional amount” (March 2013) ( PDF ) 
Subject area: Swaps


For the full list of committee reports click here.