Date: December 19, 2016
Issue: Derivatives
To: U.S. Commodity Futures Trading Commission
Filing Type: Regulatory
Description: The Coalition for Derivatives End-Users have significant concerns with the CFTC’s proposed introduction and implementation of the term “foreign consolidated subsidiary” (“FCS”) for the purposes of calculating swap dealer (“SD”) and major swap participant (“MSP”) registration thresholds. Adoption of the FCS concept would have significant adverse effects on the ability of derivatives end-users to competitively and successfully operate their commercial businesses in foreign jurisdictions, particularly because they would disadvantage U.S. commercial businesses operating in foreign jurisdictions with non-U.S. counterparties.