Skip to main content
U.S. flag

An official website of the United States government

Dot gov

The .gov means it’s official.
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you're on a federal government site.


The site is secure.
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.

Return to Comments
Capital and Margin Requirements for Covered Swap Entities 2011 Proposal
Type: Regulation
Federal Register Document Type: Proposed
No Description.

Text of Comment Letter
On behalf of seven trade associations - the ABA Securities Association, American Council of Life Insurers, Financial Services Roundtable, Futures Industry Association, Institute of International Bankers, International Swaps and Derivatives Association and Securities Industry and Financial Markets Association - attached to this email are comments regarding the treatment of inter-affiliate swap transactions under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The comments address the treatment of inter-affiliate transactions across various regulators' proposed rulemakings.



Priya Bindra

    Priya Bindra

    Davis Polk & Wardwell LLP
    450 Lexington Avenue
    New York, NY 10017

    212 450 4250   tel

    212 701 5250   fax

    Any U.S. federal tax advice contained in this e-mail (including any attachments) is not intended to be used, and cannot be used, to avoid penalties under the Internal Revenue Code or to promote, market or recommend any transaction or matter addressed herein.

    Confidentiality Note: This email is intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. Unauthorized use, dissemination, distribution or copying of this email or the information herein or taking any action in reliance on the contents of this email or the information herein, by anyone other than the intended recipient, or an employee or agent responsible for delivering the message to the intended recipient, is strictly prohibited. If you have received this email in error, please notify the sender immediately and destroy the original message, any attachments thereto and all copies. Please refer to the firm's privacy policy located at for important information on this policy.

 (See attached file: Joint.Trade.Associations.Inter-Affiliate.Swaps.Treatment.Comment.Letter.pdf)