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External Meetings: Meeting with Morgan Stanley
  
    



  Representatives from Morgan Stanley discussed the extraterritorial application of the Dodd-Frank Act (Act) requirements for swap dealers.  Specifically, the representatives asked the Commission to: (1) issue guidance on the extraterritorial reach of the Act in order to provide clarity to market participants; (2) when appropriate, defer to comparable foreign regulatory regimes; (3) harmonize the Commission’s swap rules with the security-based swap rules of the Securities and Exchange Commission; (4) through a rulemaking or interpretative guidance, address the application of transaction-level requirements on inter-affiliate transactions; and (5) implement the swap rules in a manner that does not create opportunities for regulatory arbitrage.
      
  When
              09/28/2011

  Rulemaking(s)
              I. RegistrationII. DefinitionsIII. Business Conduct Standards w/ CounterpartiesIV. Business Conduct Standards – InternalV. Capital & Margin

  CFTC Staff
              Gary GenslerGary BarnettDan BerkovitzDhaval PatelJeff BurnsCarl KennedyDavid AronTim KarpoffSarah Josephson

  Visitor(s)
              Soo-Mi LeeWilliam McCoyAnthony CiciaMichael Stein

  Organization(s)
              Morgan Stanley


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