CCT Joint Comment Letter: Comments on the Swap Dealer De Minimis Exception Preliminary Report

RE: Comments on the Swap Dealer De Minimis Exception Preliminary Report

Dear Mr. Kirkpatrick:

The Coalition for Derivatives End-Users (the “Coalition”) is pleased to respond to the request for comments by the Commodity Futures Trading Commission (“CFTC” or the “Commission”) for the Swap Dealer De Minimis Exception Preliminary Report (“Preliminary Report”).1 We urge the Commission to follow clear Congressional intent and promptly draft an interim final rule that makes clear that the swap dealer de minimis exception threshold shall remain at the $8 billion gross notional level or be raised. The Coalition is concerned that any decrease below the current $8 billion level could reduce liquidity and the availability of counterparties for end-users to trade with, thereby concentrating risk in fewer counterparties and negatively impacting end-users’ ability to hedge.

The Coalition represents end-user companies that employ derivatives to manage risks. Hundreds of companies have been active in the Coalition on both legislative and regulatory matters and our message is straightforward: financial regulatory reform measures should promote economic stability and transparency without imposing undue burdens on derivatives end-users, who are the engines of the economy. Imposing unnecessary regulation on derivatives end-users, parties that did not contribute to the financial crisis, would fuel economic instability, restrict job growth, decrease productive investment and hamper U.S. competitiveness in the global economy.

Download the full comment letter (PDF)