SEC Director, Division of Trading and Markets, Robert Cook delivered a speech before the Capital Markets and Government Sponsored Enterprises Subcommittee of the Committee on Financial Services on the ongoing implementation of Dodd-Frank Title VII, and the Commission’s efforts to address the application of the security-based swap provisions of Title VII in the cross-border context. See below for topics included in his speech:
- Ongoing regulatory coordination with the CFTC and other regulators;
- Adoption of key definitional rules;
- Adoption of rules related to clearing infrastructure;
- Proposal of capital, margin and segregation requirements;
- Issuance of implementation policy statement;
- Application of Title VII in the cross-border context; and
- Additional steps.
Lofchie Comment: Given that we are publishing speeches by two regulators on the same day on the same topic, it would be very difficult not to compare them. So I am going to do the easy thing. (Life is hard enough.) The speech by CFTC Chairman Gensler takes as its point of emphasis the percentage of rules completed by the CFTC, the number of no-action letters issued to clarify those rules, and like quantitative matters. On the other hand, the speech by Director Cook emphasizes the challenges of co-ordination with numerous domestic and international regulators and the need to develop a transparent implementation schedule. To a good extent, these speeches seem to reflect the very different approaches taken to Dodd-Frank implementation by the two regulators. Its like Venus and Mars.
View testimony in full here (links externally to SEC website).