MINUTES OF THE FEBRUARY 23, 2021 MEETING OF THE U.S. COMMODITY 

FUTURES TRADING COMMISSION’S MARKET RISK ADVISORY COMMITTEE 

The Market Risk Advisory Committee (MRAC or Committee) of the U.S. Commodity 

Futures Trading Commission (CFTC or Commission) held a public meeting on Tuesday, February 

23, 2021, at 9:30 a.m. (EST) via videoconference. The MRAC received reports from its

subcommittees: Climate-Related Market Risk, Central Clearing Counterparty (CCP) Risk and 

Governance, Market Structure, and Interest Rate Benchmark Reform. The meeting also included a 

panel on diversity, equity, and inclusion in the derivatives industry. 

MRAC Members in Attendance 

Nadia Zakir, MRAC Chair, Executive Vice President and Deputy General Counsel, Pacific 

Investment Management Company LLC (PIMCO) 

B. Salman Banaei, Executive Director, Global Head of Clearance and Settlement, IHS Markit

Stephen Berger, Managing Director and Global Head of Government & Regulatory Policy, Citadel

Richard Berner, Clinical Professor of Management Practice in Finance and Co-Director of the Stern 

Volatility and Risk Institute, NYU Stern School of Business (Special Government Employee)

Lee Betsill, Managing Director and Chief Risk Officer, CME Group 

Peter Borish, Chief Strategist, Quad Group 

Biswarup Chatterjee, Managing Director, Global Head of Innovation, Markets & Securities Services, 

Citigroup 

Alicia Crighton, Global Co-Head of Futures and Head of OTC and Prime Clearing Businesses, 

Goldman Sachs, representing Futures Industry Association (FIA)

Chris Dickens, Chief Operating Officer, Global Markets, EMEA, HSBC 

Shelly Goodwin, Compliance Director, Refining & Products Trading Americas and Global Crude, 

BP IST Global America 

Matthias Graulich, Member of the Executive Board and Chief Strategy Officer, Eurex Clearing AG 

Graham Harper, Head of Public Policy and Market Structure at DRW, representing FIA – Principal 

Traders Group 

Frank Hayden, Vice President, Trading Compliance, Calpine Corporation 

Lindsay Hopkins, Clearing House Counsel, Minneapolis Grain Exchange 

Annette Hunter, Senior Vice President and Director of Accounting Operations, Federal Home Loan 

Bank of Atlanta 

Angie Karna, Managing Director, Legal Department, Nomura Global Financial Products, Inc. 

Demetri Karousos, Chief Risk Officer, Nodal Clear, LLC, and Chief Operating Officer, Nodal 

Exchange, LLC, representing Nodal Exchange, LLC 

Eileen Kiely, Managing Director, Deputy Head of Counterparty & Concentration Risk, BlackRock 

Derek Kleinbauer, Global Head of Fixed Income & Equities Electronic Trading, Bloomberg LP and 

Vice President, Bloomberg SEF LLC 

Robert Mangrelli, Director, Chatham Financial

Kevin McClear, Corporate Risk Officer, Intercontinental Exchange, Inc. 

Dennis McLaughlin, Group Chief Risk Officer, LCH Group 

Craig Messinger, Senior Advisor, Virtu Financial 

Dale Michaels, Executive Vice President, Financial Risk Management, The Options Clearing 

Corporation 

John Murphy, Managing Director and Global Head of the Futures Division, Mizuho Americas, 

Commodity Markets Council 

Dr. Sam Priyadarshi, Principal, Global Head of Portfolio Risk Management and Derivatives, 

Vanguard 
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Marnie Rosenberg, Managing Director and Global Head of Clearinghouse Risk & Strategy, JP 

Morgan (JPM)

James Shanahan, Vice President – Financial Regulatory Compliance, CoBank ACB 

Lisa Shemie, Associate General Counsel, Cboe Global Markets and Chief Legal Officer, Cboe FX 

Markets and Cboe SEF, representing Cboe 

Dr. Betty Simkins, Head of Finance Department, Professor and Williams Companies Chair in 

Business, Oklahoma State University, Spears School of Business (Special Government 

Employee)

Tyson Slocum, Director, Energy Program, Public Citizen

Sujatha Srinivasan, Co-Head of Market Risk Specialists, Securities Division, Goldman Sachs 

Dr. Marcus Stanley, Policy Director, Americans for Financial Reform (AFR) 

Robert Steigerwald, Senior Policy Advisor, Financial Markets, Federal Reserve Bank of Chicago 

Janine Tramontana, Vice President and Senior Counsel, Federal Reserve Bank of New York 

Scott Zucker, Chief Administrative Officer, Tradeweb 

Invited Speakers in Attendance (Subcommittee Representatives)

Thomas Wipf, Chairman, MRAC Interest Rate Benchmark Reform Subcommittee; Chairman, 

Alternative Reference Rates Committee convened by the Board of Governors of the Federal 

Reserve System and the Federal Reserve Bank of New York (ARRC); Vice Chairman, 

Institutional Securities, Morgan Stanley

Bob Litterman, Chairman, MRAC Climate-Related Market Risk Subcommittee; Founding Partner 

and Risk Committee Chairman, Kepos Capital 

Invited Speakers on the Diversity, Equity and Inclusion in the Derivatives Industry Panel 

Yemi Akisanya, Director and Head of Diversity and Inclusion, Options Clearing Corporation 

Keisha M. Bell, Head of Diverse Talent Management and Advancement, DTCC 

Erika Irish Brown, Chief Diversity Officer, Goldman Sachs 

Leslie Schreiner, Director of Diversity and Inclusion, Federal Home Loan Bank of Atlanta 

Sacha Thompson, CEO & Founder, The Equity Equation LLC 

CFTC Commissioners and Staff in Attendance 

Rostin Behnam, Acting Chairman and MRAC Sponsor 

Dan M. Berkovitz, Commissioner 

Brian D. Quintenz, Commissioner 

Dawn D. Stump, Commissioner 

David Gillers, Climate-Related Market Risk Subcommittee Alternate Designated Federal Officer, 

Chief of Staff, Office of Acting Chairman Behnam 

Alicia L. Lewis, MRAC Designated Federal Officer (DFO), Special Counsel, Office of Acting 

Chairman Behnam 

I. Welcome and Opening Remarks 

Ms. Lewis called the meeting to order. CFTC Acting Chairman Behnam then welcomed

everyone and thanked the Commissioners, MRAC members, subcommittee chairs, and speakers, as 

well as MRAC Chairwoman Zakir, Ms. Lewis, and Mr. Gillers, for their work in support of the 

MRAC. He stated that the CFTC is closely monitoring recent activity in the precious metals markets 

and irregularities in the Texas energy markets, and has remained vigilant in carrying out its mission 

and mandate. Turning to the agenda, Acting Chairman Behnam noted that all four of the MRAC 

subcommittees would be providing updates, and then provided an overview of the important work 
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and successes of each subcommittee. Regarding the transition to LIBOR, he praised the successful 

launch of the ISDA 2020 IBOR Fallbacks Protocol and widespread market adherence. However, he 

stated that even firms with one or two open swaps should have a plan for transition and cautioned 

that if there are large, active firms that have not adhered to the ISDA protocol, “relevant regulators 

and counterparties will be apt to take notice.” He noted that the meeting would end with a panel on 

diversity, and said that it’s time to start a more fulsome dialogue on how the failure to incorporate 

diversity and foster inclusion in our markets may negatively impact our economic future. 

Commissioners Quintenz, Stump, and Berkovitz thanked everyone for their hard work on 

behalf of the MRAC. Commissioner Quintenz praised Acting Chairman Behnam’s early formation 

of the Interest Rate Benchmark Subcommittee, which played a crucial rule in the transition from 

LIBOR, and commended the work of the Market Structure, CCP Risk and Governance, and ClimateRelated Market Risk Subcommittees. Commissioner Stump emphasized that the CFTC’s role is to 

ensure that derivatives markets function properly for the purpose of price discovery and risk 

management, and expressed concern that the press and social media may incorrectly suggest that the 

CFTC is promoting rather than merely monitoring developments in products that it regulates, such as 

bitcoin and carbon emission controls. Commissioner Berkovitz stated that the catastrophe in Texas 

illustrates the importance of market design and structure in meeting critical energy and infrastructure 

needs, and it will be important to examine the causes and incorporate any lessons learned. 

II. Report from the Interest Rate Benchmark Reform Subcommittee

Mr. Wipf, Chairman of the Interest Rate Benchmark Reform Subcommittee, discussed recent 

developments in the transition from LIBOR. He noted that in October 2020, CME and LCH 

successfully executed their respective discounting transitions. Also in October, ISDA launched its 

IBOR Fallbacks Protocol and Supplement, marking a major milestone in the transition from 

interbank offered rates (IBORs) globally. These documents provide fallback language for derivative 

transactions, reducing the risk of market disruption if a key interbank lending rate ceases to exist or 

LIBOR is deemed to be non-representative before the transition efforts are complete. Over 13,000 

entities have adhered to this protocol, and both CME and LCH have incorporated fallback terms into 

their rulebooks, so that at this point the entire cleared market and much of the uncleared market is 

operating with ISDA’s fallbacks. 

Mr. Wipf explained that in the loan market, which has struggled with adoption of the Secured 

Overnight Financing Rate (SOFR), U.S. regulators provided clarity towards the end of last year 

related to credit-sensitive benchmark rates and appropriate benchmarks to be used in loans. He noted 

that the most important development occurred in late November, when the ICE Benchmark 

Administration (IBA), the administrator of LIBOR, released a consultation proposing cessation dates 

for the 35 LIBOR settings they publish. They proposed to cease publication of all tenors of Sterling, 

Euro, Swiss Franc and Japanese Yen LIBOR as well as 1 week and 2 month USD LIBOR on 

December 31, 2021, and cease publication of the Overnight and 1, 3, 6 and 12 month USD LIBOR 

settings on June 30, 2023. This consultation concluded in January, and the Interest Rate Benchmark 

Reform Subcommittee is awaiting the final results. Notification by IBA of the exact timeline for 

LIBOR cessation would serve to freeze the spread adjustments to be used in derivatives that use 

ISDA’s fallback as well as cash products that use the ARRC-approved fallbacks. On the same day 

that IBA published this consultation, the Federal Reserve Board of Governors, the Federal Deposit 

Insurance Corporation and the Office of the Comptroller of the Currency published supervisory 

guidance on LIBOR activity that encouraged banks to cease entering into new contracts that use USD 

LIBOR as a reference rate as soon as practicable and in any event by December 31, 2021. New 
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contracts entered into before December 31, 2021, should either utilize a reference rate other than 

LIBOR or have robust fallback language that includes a clearly defined alternative reference rate 

after LIBOR’s discontinuation. Mr. Wipf stated that every firm needs to accelerate their LIBOR 

transition plans in order to comply with this guidance. Additionally, LCH and CME have provided 

indications on how they would approach a LIBOR cessation event from an operational and risk 

management perspective, and that these proposals will form the next workstream for the Interest Rate 

Benchmark Reform Subcommittee. He also reviewed recent CCP proposals for transitioning away 

from LIBOR. There were no questions or comments from the MRAC members. 

III. Report from the Climate-Related Market Risk Subcommittee 

Mr. Litterman discussed the Climate-Related Market Risk Subcommittee’s report, 

“Managing Climate Risk in the U.S. Financial System.” He stated that the central message of the 

report is that U.S. financial regulators must recognize that climate change poses serious risks to the 

U.S. financial system, and should move urgently and decisively to measure, understand, and address 

these risks as well as to help increase the flow of capital toward building the net-zero economy of the 

future. He provided an overview of the report’s key recommendations, including that financial 

markets may be able to channel resources efficiently and at the scale needed to activities that reduce 

greenhouse gas emissions if and only if an economy-wide price on carbon is in place that reflects the 

true social cost of such emissions. Mr. Litterman reviewed each chapter of the report, and 

highlighted four recommendations that are directed specifically to the CFTC in detail

(Recommendations 4.11, 4.16, 7.7 and 8.5 of the report). He focused attention on the need to 

establish an effective price on carbon, which he said is the root cause of climate change. He stated

that the problem can be easily fixed by a small change in the tax code that will create appropriate 

incentives to reduce emissions and significant revenues that governments need to address climate 

challenges. 

In the ensuing discussion by MRAC members, a participant suggested that the CFTC should 

engage the cash carbon markets. Another participant stressed the importance of high-quality 

disclosure by companies, including business plans in a net-zero economy, and supported moving to a 

single global disclosure standard. Commissioner Berkovitz asked what the Climate-Related Market 

Risk Subcommittee foresees as the role of agencies like the CFTC in implementing a disclosure 

regime, and whether they would set standards for disclosures and review them, or that would be left 

to market participants. Mr. Litterman replied that disclosures of climate-related risk are different 

than typical financial risks and risk factors may vary for different industries, and therefore the 

Climate-Related Market Risk Subcommittee believes this will be an iterative process that will require 

regulators to work with each other and the financial industry to develop standards for disclosure of 

material risks.

IV. Report from the Market Structure Subcommittee

Mr. Berger, co-chair of the Market Structure Subcommittee, presented the Subcommittee’s 

report on the “made available to trade” (MAT) process, which includes four principal 

recommendations: (1) provide the CFTC with the authority through its rulemaking process to 

determine that a swap is MAT; (2) enhance the criteria used when either the CFTC or swap execution 

facilities (SEFs) make a MAT determination; (3) lengthen the time between when a MAT 

determination is made and when the trade execution requirement becomes effective from 30 days to 

90 days; and (4) create additional avenues for certain existing MAT swaps to no longer be subject to 

the trade execution requirement. The report also highlights three areas for future consideration: (1) 
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creation of an industry advisory body to advise on the scope of the trade execution requirement; (2) 

whether a MAT determination means that only “outright” transactions in a swap are subject to the 

trade execution requirement or any “package” transactions that include that swap are subject to the 

trade execution requirement; and (3) whether it may be appropriate to suspend the trade execution 

requirement due to technical outages at one or more SEFs or a major market disruption. 

During the discussion of the report by MRAC members, one participant suggested that if the 

Commission moves forward with an enhanced CFTC-initiated MAT process, it should replace the 

current SEF-initiated process, and if the SEF-initiated process is retained, it should be subject to the 

same enhancements being recommended for the CFTC-initiated process, such as the notice and 

comment requirement. She noted that many of the report’s recommendations were drawn from the 

CFTC’s 2018 proposed rule, and suggested that other aspects of that proposal are worthy of being 

revisited. Another participant suggested that, from the perspective of the end-user, the CFTC should 

consider the interplay between the MAT determination and regulatory-established block size limits, 

because once a contract is subject to MAT, it becomes subject to pre-trade price transparency, which 

makes efficient execution of large risk transfers more complex, so that calibration of block sizes may 

be needed, especially during stressed markets. This participant stated that a more pressing 

consideration is the interplay between the MAT determination and the imminent cessation of LIBOR, 

which will create a real-world test for how the MAT determination adjusts to market liquidity. She

also stated that LIBOR swaps are subject to MAT, while alternative reference rate swaps are not, so 

as the market transitions away from LIBOR, the CFTC should actively prepare for how to MAT and 

de-MAT the relevant contracts. Following the discussion, the MRAC voted on the Market Structure 

Subcommittee’s motion that the Committee adopt the subcommittee’s report regarding the MAT 

process and that it be submitted to the Commission for consideration. The motion was approved by 

the Committee with 30 “yes” votes, 0 “no” votes, and 3 abstentions. 

Ms. Shemie, co-chair of the Market Structure Subcommittee, then presented the 

subcommittee’s report regarding the swap dealer (SD) landscape, which focused on ways to 

encourage liquidity and diversity among liquidity providers trading on SEFs and designated contract 

markets (DCMs) without undermining the goal of SD regulation. The report recommended that the 

Commission exempt swaps that are exchange-traded and centrally cleared from the SD registration 

threshold calculation. The report also recommended that the CFTC explore additional modifications 

to increase liquidity, such as exempting swaps that are exchange-traded but not centrally cleared 

from SD registration to the extent they are traded through a prime broker that is a registered SD

(primarily foreign exchange options and non-deliverable forwards), and pursue fact finding to better 

understand why certain firms are reluctant to register as floor traders notwithstanding no-action 

relief. 

During the ensuing discussion by MRAC members, one participant strongly opposed the 

recommendation to exempt cleared and/or exchange-traded swaps from the de minimis calculation 

for SD designation, noting that the Commission reconsidered and dropped that idea from the final 

rule. This participant stated that it would be an abrogation of the CFTC’s responsibilities to provide 

this exemption given that the majority of volume in a lot of very systemically important derivatives 

markets is exchange-traded and/or cleared, and that Congress would have made the exemption clear 

in Dodd-Frank had an exemption been intended. Another participant suggested that a study and 

analysis be conducted, either by the CFTC or a third party, before any recommendations are 

considered, in order to identify what kind of firms would take advantage of this exemption and how 

much liquidity they would add, as well as the kind of risks that these firms would bring to the market. 

Another participant stated that further analysis is needed to support the report’s central assertion that 
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the recommendations would increase liquidity and diversity among liquidity providers on SEFs. 

Following the discussion, the MRAC voted on the Market Structure Subcommittee’s motion that the 

Committee adopt the subcommittee’s report regarding the swap dealer landscape and that it be 

submitted to the Commission for consideration. The motion was approved by the Committee with 27

“yes” votes, 4 “no” votes, and 2 abstentions. 

V. Report from the CCP Risk and Governance Subcommittee

Mr. Betsill, co-chair of the CCP Risk and Governance Subcommittee, gave a brief overview 

of the subcommittee’s work and then presented its report on CCP Governance. He explained that the 

report’s recommendations reflect the varying perspectives of clearing member and end-user

representatives and CCPs, and a summary of subcommittee constituent perspectives is included in 

the report. The report provides recommendations in two key areas where agreement was reached. 

First, the report recommends that CFTC rules require all derivatives clearing organizations (DCOs) 

to establish and regularly schedule one or more market participant risk advisory working groups as a 

forum to seek risk-based views from a broad array of market participants, including clearing 

members and end-users, in the early stages of proposing changes that could materially affect the 

DCO’s risk profile. Second, the report recommends that CFTC rules require a DCO to have 

governance arrangements that establish one or more risk management committees (RMCs) and 

require the board of directors to consult with and consider feedback from these RMCs on all matters 

and proposed changes to the DCO’s rules, procedures, or operations that could materially affect the 

DCO’s risk profile, including any material change to the DCO’s risk model, default procedures, 

participation requirements, and risk monitoring practices, as well as the clearing of new products that 

could significantly impact the DCO’s risk profile. Further, the report recommends that a DCO 

establish and enforce appropriate fitness standards for members of each RMC, and maintain policies 

to make certain that members of each RMC are able to provide a risk-based independent, informed 

opinion on all matters presented to the RMC for consideration and perform their duties in a manner 

that supports the safety and efficiency of the DCO and the stability of the broader financial system, 

and that RMCs include representatives from market participants. The final recommendation is that 

DCOs maintain policies to ensure that membership of each RMC is reconstituted on a regular basis. 

The MRAC members then discussed the report. One participant supported the 

recommendations but said that because the downside of a CCP failure is disproportionately borne by 

non-defaulting market participants, the recommendations should be expanded to matters highlighted 

in the papers which did not receive CCP support, such as margin anti-procyclicality measures, and 

that additional work should be done to ensure that market participants have the opportunity for notice 

and comment on matters that materially impact the risk profile of a CCP. This participant also 

recommended that the subcommittee continue to develop actionable recommendations in the areas of 

CCP transparency, incentives, stress testing, liquidity, and default management. Another participant

agreed with the previous comment, adding that key areas for further progress would include 

regulatory reevaluation of minimum margin requirements and the data and methodologies on which 

they are based, noting that this may support a more prescriptive approach than is called for in the 

margin report. This participant would support a formal comment period ahead of new CCP rule 

filings, allowing for consultation with clearing members, customers, and the public, increased 

transparency for CCP risk management, particularly margin methodologies, and a requirement for 

DCO capital contributions to the default waterfall. Another participant agreed with the previous 

comments and stressed the need for regulators periodically to reevaluate minimum margin regulatory 

requirements and measures to reduce procyclicality in CCPs and markets. Following the discussion, 

the MRAC voted on the CCP Risk and Governance Subcommittee’s motion that the Committee 
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adopt the subcommittee’s report containing recommendations on CCP governance and a summary of 

subcommittee constituent perspectives and that it be submitted to the Commission for consideration. 

The motion was approved by the Committee with 31 “yes” votes, 0 “no” votes, and 1 abstention. 

Ms. Crighton, co-chair of the CCP Risk and Governance Subcommittee, presented its paper 

on best practices in CCP margin methodologies, which includes six recommendations: First, the 

CFTC should enhance its flexible approach to supervising how CCPs manage procyclical margin 

requirements that prioritizes the desired outcome of reducing procyclicality and not the specific

means of reducing it, recognizing that CCPs may employ a range of tools to measure and manage 

procyclicality that are uniquely tailored to the products and markets they clear. Second, CCPs should 

be allowed flexibility to apply margin add-ons that consider the impact of liquidity and portfolio 

concentration on expected closeout costs, based on market depth and position exposures and 

consideration of certain factors enumerated in the report. Third, the CFTC should promote the use of 

scheduled/predictable event-driven and routine intraday variation settlement cycles to prevent the 

accumulation of current exposures at CCPs as appropriate. In addition, CCPs should be allowed the 

discretion to manage intraday exposures with unscheduled/not predictable event-driven intraday 

margin calls under certain conditions enumerated in the report. Fourth, the CFTC should consider 

certain principles enumerated in the report when evaluating the appropriateness of a CCP’s margin 

period of risk (MPOR) assumption. Fifth, CCPs should have a robust framework for determining 

end-of-day settlement prices and theoretical intraday pricing, incorporating certain principles 

discussed in the report. Sixth, CCP margin methodologies should be sufficiently transparent so that 

market participants can understand how models react to certain market conditions for liquidity 

planning and risk management purposes. 

During the discussion by MRAC members, one participant supported the ideas in both the 

governance and margin papers, but urged the CFTC and global regulators to pay careful attention to 

areas of disagreement, noting that when markets cannot agree upon the right outcome, it is often 

incumbent upon the regulatory community to step in. Another participant supported the 

recommendations, but welcomed further work on margin procyclicality and related disclosures by 

regulators, and continued development of recommendations pertaining to issues of CCP transparency 

and disclosures and CCP capital, including with respect to both default and non-default losses. With 

respect to RMCs, this participant specifically highlighted that the requirement for CCPs to formally 

consult market participants on any rule change that can materially affect the CCP’s risk profile before 

filing a rule submission was not agreed upon by the full subcommittee, but encouraged the CFTC to 

nevertheless consider it and other recommendations that were not agreed upon. A third participant 

noted that procyclicality continues to be an area of concern. With regard to MPOR, this participant 

suggested that further study needs to be done to ensure that, rather than targeting specific numbers, 

adequate time is spent to ensure that as market conditions and market liquidity change, the MPOR 

followed by a certain CCP for its risk models is appropriate for those market conditions. Another 

participant clarified that in the white paper on procyclicality that LCH recently released, it did not 

change risk parameters or the risk process. Commissioner Berkovitz added that procyclicality issues 

don’t appear to be the tail or black swan anymore, as 100-year events (e.g., the pandemic, the WTI 

price issue last April, and California fires) are occurring with increasing frequency. Following the 

discussion, the MRAC voted on the CCP Risk and Governance Subcommittee’s motion that the 

Committee adopt the subcommittee’s report on CCP margin methodologies and that it be submitted 

to the Commission for consideration. The motion was approved by the Committee with 28 “yes” 

votes, 0 “no” votes, and 2 abstentions. 
leaders that drive the strategy and own the effort; (2) the role that individual employees can play; (3) 

barriers to success for underrepresented employees; ( 4) the internal and/or external response of 

organizations to global protests for equity and in particular racial equity, and to racial injustice and 

systemic racism; (5) creating a culture where employees feel comfortable discussing race; (6) the 

importance of intersectionality, reflecting that people may have multiple identities which may not 

align to one group alone, as opposed to a singular focus; (7) how to make employees feel included and able to show up as their 100 percent authentic selves; (8) being an ally or "upstander" (a person 

who speaks or acts in support of an individual) vs. a bystander; (9) sponsorship (using privilege or 

position to advocate for someone and provide opportunities, such as access to your network) vs. 

mentorship (merely advising); (10) equity (providing support or removing barriers to create an equal 

playing ground and help the most marginalized employees, including recruitment and retention goals 

from these groups) vs. equality (giving everybody the same thing); (11) measuring success in DE&I 

initiatives; and (12) effective measures that organizations can put into place to address DE&I, and 

build a diverse pipeline of talented employees. During the Q&A, in response to a question about the 

role that the CFTC can play in furthering progress, a panel member said that it is very helpful for 

regulators to set at least a minimum standard of for organizations with respect to DE&I. 

VII. Closing Remarks 

Commissioners Berkovitz, Stump, and Quintenz each indicated that they found the 

information discussed in the DE&I panel, as well as all of the other reports, very informative, and 

they thanked the participants. Commissioner Quintenz added that he would like to recognize the 

recommendation on de minimis thresholds, as he has long called for a full-scale rationalization of the 

SD registration framework, including exempting exchange traded or cleared swaps from the de 

minimis calculation. Acting Chairman Behnam noted that the panel on DE&I was the first of its kind 

for the agency, and thanked Ms. Lewis for putting the panel together and Ms. Zakir for moderating a 

fantastic panel. He then thanked all of the panelists and attendees for their participation. Ms. Lewis 

thanked everyone for being engaged and adjourned the meeting at 2:21 p.m. 

I hereb certify that the foregoing minutes are accurate. 

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