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Better Markets Comment Letter on Capital Requirements for Swap Dealers and Major Swap Participants

On March 3, 2020, Better Markets filed a comment letter addressing the CFTC’s re-proposal of certain elements of a 2016 proposal on capital requirements for certain swap dealers (SDs), and others, under Title VII of the Dodd-Frank Act.  The SD capital requirements are among the most consequential derivatives reforms in Title VII of the Dodd-Frank Act, raising issues directly relevant to the CFTC’s public interest mandate and the safety and soundness of SDs and the U.S. financial system.