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Capital and Margin Requirements for Covered Swap Entities

On behalf of seven trade associations - the ABA Securities Association, American Council of Life Insurers, Financial Services Roundtable, Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association and Securities Industry and Financial Markets Association - attached to this email are comments regarding the treatment of inter-affiliate swap transactions under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The comments address the treatment of inter-affiliate transactions across various regulators' proposed rulemakings.



Priya Bindra

Priya Bindra

Davis Polk & Wardwell LLP
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 Joint.Trade.Associations.Inter-Affiliate.Swaps.Treatment.Comment.Letter.pdf - Joint.Trade.Associations.Inter-Affiliate.Swaps.Treatment.Comment.Letter.pdf