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“We appreciate the SEC taking a thoughtful approach to this critical issue, and for moving forward through the appropriate rulemaking processes. The swaps market is truly global in nature and US regulators must work with their counterparts in Europe and Asia to ensure that regulatory oversight of these markets is coordinated and harmonised.
“We look forward to closely analysing the SEC’s use of ‘substituted compliance'. We believe that foreign regulations should be assessed on a comprehensive, ultimate outcome-level basis, not rule-by-rule nor transaction-by-transaction. This will be critical to working effectively with foreign regulatory bodies to oversee global markets for these products.”