Retirement: Financial Reform / Swaps
Legislative proposals, bills and analysis from the 109th and 110th Congresses (2006-present)
Regulatory administrative rules and information from U.S. offices and agencies
Judicial current and past court cases and amicus briefs
Press Releases Council statements and advisories to the news media
(Items in italic are available only to Council members.)
Official Source Documents
September 23, 2011 Retirement Income Protection Act (H.R. 3045)
June 23, 2011 SEC Regulatory Accountability Act (H.R. 2308)
June 3, 2011 2012 Agriculture Department Spending Bill (H.R. 2112)
May 4, 2011 Bill to Facilitate Implementation of Dodd-Frank Act (H.R. 1573), as approved by House Agriculture Committee
April 15, 2011 Bill to Facilitate Implementation of Dodd-Frank Act (H.R. 1573)
July 21, 2010 The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (As Enacted)
July 15, 2010 The American Financial Stability Act (H.R. 4173) (as passed by House and Senate)
July 15, 2010 Senate Colloquies Regarding Pension Implications of the American Financial Stability Act (H.R. 4173)
June 23, 2010 Conference Committee House Proposed Amendment to Title VII (Derivatives Provisions) of American Financial Stability Act (H.R. 4173)
June 23, 2010 Official Summary of the House Proposed Amendment to Title VII (Derivatives Provisions) of American Financial Stability Act (H.R. 4173)
June 22, 2010 Conference Committee Manager's Amendment to Title X (CFPB Provisions) of American Financial Stability Act (H.R. 4173)
June 22, 2010 Conference Committee House Proposed Amendment to Title X (CFPB Provisions) of American Financial Stability Act (H.R. 4173)
June 10, 2010 Summary of Conference Committee Base Text of Restoring American Financial Stability Act (HR 4173)
June 10, 2010 Conference Committee Base Text of Restoring American Financial Stability Act (HR 4173)
April 29, 2010 Restoring American Financial Stability Act (S. 3217)
April 21, 2010 Wall Street Transparency and Accountability Act (Lincoln)
Council Materials
November 15, 2011 Council/CIEBA Letter of Support for H.R. 3045 and H.R. 2586
February 15, 2011 Council Testimony on Swaps Regulations Before House Agriculture Subcommittee on General Farm Commodities and Risk Management
June 11, 2010 Employer Letter to Senate Financial Services Reform Bill Conferees Regarding Swaps
June 11, 2010 Employer Letter to House Financial Services Reform Bill Conferees Regarding Swaps
June 11, 2010 Action Alert Urging Congress to Change Financial Services Reform Legislation Regarding Stable Value Funds
June 11, 2010 Stable Value Swaps Proposal
June 11, 2010 Stable Value Swaps Proposed Language
May 28, 2010 ACTION ALERT: Urge Lawmakers to Address Swaps Provisions in Financial Legislation
May 19, 2010 Council Letter to Senate Regarding Swaps Legislation
May 14, 2010 ACTION ALERT: Urge Senators to Fix Swaps Legislation
May 5, 2010 Group Letter to Senate Regarding Swaps Provision of Financial Regulatory Legislation
April 21, 2010 Council Letter to Senator Casey Regarding Swaps Legislation
April 19, 2010 Group Letter to Senate Agriculture, Nutrition & Forestry Committee Regarding Swaps Legislation
Official Source Documents
February 7, 2013 DOL Advisory Opinion Regarding Application of ERISA to Cleared Swaps Transactions
August 13, 2012 CFTC/SEC Final Regulations Defining “Swap,”’ “Security-Based Swap” and “Security-Based Swap Agreement”
May 30, 2012 CFTC Proposed Regulations on Aggregation, Position Limits for Futures and Swaps
- Clarification/Correction (July 5, 2012)
January 18, 2012 CFTC Final Regulations on Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties
January 17, 2012 Phyllis Borzi/DOL-EBSA Letter to CFTC Regarding Final Regulations on Business Conduct Standards
January 11, 2012 CFTC Questions & Answers on Final Business Conduct Standards Rules
January 11, 2012 CFTC Fact Sheet on Final Business Conduct Standards Rules
November 18, 2011 CFTC Final and Interim Final Regulations on Position Limits for Futures and Swaps
August 25, 2011 CFTC/SEC Request for Comment on Study of Stable Value Contracts under Dodd-Frank
July 19, 2011 CFTC Final Order Regarding Effective Date for Swap Regulation
July 18, 2011 SEC Final Regulations Regarding Business Conduct Standards for Security-Based Swap Dealers and Major Security-Based Swap Participants
June 17, 2011 CFTC Notice of Proposed Order Regarding Effective Dates for Swaps Regulations
May 11, 2011 Prudential Regulators’ Proposed Regulations on Margin and Capital Requirements for Covered Swap Entities
April 28, 2011 CFTC Extension of Comment Period for Dodd-Frank Implementation
April 26, 2011 CFTC/SEC Announcement of Joint Roundtable Discussion and RFI
April 25, 2011 CFTC Proposed Regulations on Swap Data Recordkeeping and Reporting Requirements
April 12, 2011 CFTC Proposed Regulations on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
March 16, 2011 CFTC Proposed Regulations on Clearing Agency Standards for Operation and Governance
January 7, 2011 CFTC Proposed Regulations Regarding Core Principles and Other Requirements for Swap Execution Facilities
December 28, 2010 CFTC Proposed Regulations on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants
December 23, 2010 CFTC Proposed Regulations Regarding Swap Data Repositories
December 22, 2010 CFTC Proposed Regulations Regarding Business Conduct Standards for Swap Dealers, Participants
December 21, 2010 CFTC Proposed Regulations Regarding Further Swap-Related Definitions
December 9, 2010 CFTC Proposed Regulations on Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants
December 8, 2010 CFTC Proposed Regulations on Swap Data Recordkeeping and Reporting Requirements
December 7, 2010 CFTC Proposed Regulations on Real-Time Reporting of Swap Transaction Data
November 2, 2010 CFTC Proposed Rule for Process for Review of Swaps for Mandatory Clearing
November 2, 2010 CFTC Proposed Rule for Provisions Common to Registered Entities
Council Materials
February 1, 2013 Council Letter to DOL Regarding Needed Guidance on Treatment of Swaps Transactions under ERISAOctober 31, 2012 Council Letter to CFTC/SEC Regarding Study of Stable Value Contracts under Dodd-Frank (Second Submission)
September 14, 2012 Group Comments on Proposed Rules Related to Margin for Uncleared Swaps
June 29, 2012 Council Letter to CFTC Regarding Aggregation, Position Limits for Futures and Swaps
January 25, 2012 Council Summary of CFTC Final Business Conduct Standards with Respect to ERISA Plans Under Dodd-Frank (Prepared by Davis & Harman LLP)
September 26, 2011 Council Letter to CFTC/SEC Regarding Study of Stable Value Contracts under Dodd-Frank
August 29, 2011 Council Comment Letter to SEC on Proposed Business Conduct Standards Regulations
June 3, 2011 Council/CEIBA Letter to CFTC Regarding Business Conduct Standards
May 6, 2011 Council Letter to SEC Regarding Clearing Agency Standards for Operation and Governance
March 25, 2011 Council/CIEBA Letter to NY Federal Reserve Regarding Swaps
March 8, 2011 Council/CEIBA Letter to CFTC Regarding Core Principles and Other Requirements for Swap Execution Facilities
March 8, 2011 Council/CEIBA letter to CFTC Regarding Swap Execution Facilities
February 28, 2011 Council/CEIBA Letter to CFTC Regarding Confirmation, Portfolio Reconciliation and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants
February 22, 2011 Group Letter to CFTC Regarding Business Conduct Standards
February 22, 2011 Council/CEIBA Letter to CFTC Regarding Business Conduct Standards
February 22, 2011 Council/CEIBA Letter to CFTC Regarding Various Definitions
February 22, 2011 Council/CEIBA Letter to CFTC Regarding Swap Data Repositories
February 7, 2011 Council Letter to CFTC Regarding Unique Counterparty Identifiers
February 7, 2011 Council/CIEBA Letter to CFTC Regarding Swaps Issues
January 31, 2011 Council Comment Letter to Treasury Regarding Legal Entity Identifiers
January 3, 2011 Council Comment Letter to CFTC Regarding Process for Review of Swaps for Mandatory Clearing and Provisions Common to Registered Entities
November 18, 2010 Council/CIEBA Comments to SEC Regarding Proposed Rule Defining "Family Offices"
November 5, 2010 Council/CIEBA Talking Points: Major Swap Participant Status Would Harm Plans and Plan Participants
November 1, 2010 Council/CIEBA PowerPoint on Developing Standardization, Clearing and Anti-Evasion Models for ERISA Pension Plan Swaps
November 1, 2010 Council/CIEBA PowerPoint on Segregation of Customer Margin for Cleared Swaps
November 1, 2010 Summary and Analysis of DOL Proposed Regulation on Fiduciary Definition (Courtesy of Davis & Harman, LLP)
October 19, 2010 Council/CIEBA Talking Points: Applicability of Business Conduct Standards to ERISA Plans
September 20, 2010 Joint Council/CIEBA Letter to CFTC/SEC Regarding Definitions of Major Swap Participant and Major Security-Based Swap Participant
September 8, 2010 Council Letter to CFTC and SEC Regarding Swap Trade Rules and Business Conduct Standards
August 17, 2010 Council/CIEBA Letter to ISDA Regarding Draft Derivatives Proposal
June 22, 2010 Council Letter to DOL Regarding Technical Assistance on Financial Services Legislation

Council commends CFTC's revision of business conduct standards
January 11, 2012
Council, CIEBA testify: Dodd-Frank regulatory process moving too quickly, could adversely affect pension plans
February 15, 2011
Council conference call to brief media on financial services reform bill impact on swaps in retirement plans
June 15, 2010
Passage of pension funding relief a crucial step toward economic recovery, but long-term solutions still needed
May 28, 2010
Council urges support for pension 'swaps' amendment to Senate financial services reform legislation
May 19, 2010


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