Date: December 19, 2016

Issue: Derivatives

To: U.S. Commodity Futures Trading Commission 

Filing Type: Regulatory

Description: The signatories believe that the FCS Cross-Border Application of the Registration Thresholds and External Business Conduct Standards Applicable to Swap Dealers and Major Swap Participants as it is proposed would (i) have a detrimental impact on U.S. swaps market participants, particularly Main Street businesses seeking to prudently hedge their commercial and market risks when they do business in foreign jurisdictions; (ii) represent an unprecedented approach to regulating financial markets that is inconsistent with principles of international comity; and (iii) be excessively costly to implement without resulting in a commensurate reduction in systemic risks to U.S. financial markets. Accordingly, we respectfully request that the CFTC refrain from moving forward with the application of the FCS concept as described or alluded to in the Proposed Cross-Border Rule.

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