Swap Data Repositories: Interpretative Statement Regarding the Confidentiality and Indemnification Provisions of Section 21(d) of the Commodity Exchange Act, 26709-26713 [2012-10918]
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Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
products will continue to be subject to
FDA evaluation for safety and FSIS
evaluation for suitability. Company
costs and the agencies’ costs associated
with these evaluations will not be
affected by this proposed rule should it
become final. The only change would be
the process for listing the substances
specified in this proposal after they
have been approved.
Regulatory Flexibility Act
Pursuant to section 605(b) of the
Regulatory Flexibility Act, 5 U.S.C.
605(b), the FSIS Administrator has
made a preliminary determination that
this proposed rule will not have a
significant impact on a substantial
number of small entities. This
determination is based primarily on the
fact that the proposed rule would not
affect the process for approving new
uses of sodium benzoate, sodium
propionate, and benzoic acid in meat or
poultry products. This proposed rule
would make the process of listing
approved uses of these substances more
efficient by eliminating the need for
FSIS to conduct rulemaking each time a
new use is approved.
Paperwork Reduction Act
This rule does not contain any new
information collection or record keeping
requirements that are subject to the
Office of Management and Budget
(OMB) approval under the Paperwork
Reduction Act, 44 U.S.C. 3501, et seq.
E-Government Act
FSIS and USDA are committed to
achieving the purposes of the EGovernment Act (44 U.S.C. 3601, et
seq.) by, among other things, promoting
the use of the Internet and other
information technologies and providing
increased opportunities for citizen
access to Government information and
services, and for other purposes.
srobinson on DSK4SPTVN1PROD with PROPOSALS
Executive Order 12988
This proposed rule has been reviewed
under Executive Order 12988, Civil
Justice Reform. This proposed rule: (1)
Has no retroactive effect; and (2) does
not require administrative proceedings
before parties may file suit in court
challenging this rule. However, the
administrative procedures specified in 9
CFR 306.5, 381.35, and 590.300 through
590.370, respectively, must be
exhausted before any judicial challenge
may be made of the application of the
provisions of the proposed rule, if the
challenge involves any decision of an
FSIS employee relating to inspection
services provided under the FMIA,
PPIA, or EPIA.
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Additional Public Notification
FSIS will announce the availability of
this proposed rule on-line through the
FSIS Web page located at https://
www.fsis.usda.gov/
regulations_&_policies/
Federal_Register_Proposed_Rules/
index.asp.
FSIS also will make copies of this
Federal Register publication available
through the FSIS Constituent Update,
which is used to provide information
regarding FSIS policies, procedures,
regulations, Federal Register notices,
FSIS public meetings, and other types of
information that could affect or would
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subscription service for industry, trade,
and farm groups, consumer interest
groups, allied health professionals,
scientific professionals, and other
individuals who have requested to be
included. The Update also is available
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and the Web page, FSIS is able to
provide information to a much broader,
more diverse audience.
In addition, FSIS offers an email
subscription service which provides
automatic and customized access to
selected food safety news and
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Options range from recalls to export
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have the option to password-protect
their accounts.
List of Subjects in 9 CFR Part 424
Food additives, Food packaging, Meat
inspection, Poultry and poultry
products.
For the reasons set forth in the
preamble, FSIS proposes to amend 9
CFR part 424 as follows:
PART 424—PREPARATION AND
PROCESSING OPERATIONS
1. The authority citation for part 424
would continue to read as follows:
Authority: 7 U.S.C. 450, 1901–1906; 21
U.S.C. 451–470, 601–695; 7 CFR 2.18, 2.53.
2. Revise § 424.23(a)(3) as follows:
§ 424.23
Prohibited uses.
*
*
*
*
*
(a) * * *
(3) Sorbic acid, calcium sorbate,
sodium sorbate, and other salts of sorbic
acid shall not be used in cooked
sausages or any other meat; sulfurous
acid and salts of sulfurous acid shall not
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26709
be used in or on any meat; and niacin
or nicotinamide shall not be used in or
on fresh meat product; except that
potassium sorbate, propylparaben
(propyl p-hydroxybenzoate), and
calcium propionate, may be used in or
on any product, only as provided in 9
CFR chapter III.
*
*
*
*
*
Done at Washington, DC, on May 1, 2012.
Alfred V. Almanza,
Administrator.
[FR Doc. 2012–10871 Filed 5–4–12; 8:45 am]
BILLING CODE 3410–DM–P
COMMODITY FUTURES TRADING
COMMISSION
17 CFR Part 49
RIN 3038–AD83
Swap Data Repositories: Interpretative
Statement Regarding the
Confidentiality and Indemnification
Provisions of Section 21(d) of the
Commodity Exchange Act
Commodity Futures Trading
Commission.
ACTION: Proposed interpretative
statement.
AGENCY:
The Commodity Futures
Trading Commission (‘‘Commission’’ or
‘‘CFTC’’) is proposing this interpretative
statement to provide guidance regarding
the applicability of the confidentiality
and indemnification provisions set forth
in new section 21(d) of the Commodity
Exchange Act (‘‘CEA’’) added by section
728 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act
(‘‘Dodd-Frank Act’’). The Commission
requests comment on all aspects of the
proposed interpretative statement. The
proposed interpretative statement
clarifies that the provisions of section
21(d) should not operate to inhibit or
prevent foreign regulatory authorities
from accessing data in which they have
an independent and sufficient
regulatory interest, even if that data also
has been reported pursuant to the CEA
and Commission regulations.
DATES: Comments must be received on
or before June 6, 2012.
ADDRESSES: Comments, identified by
RIN number 3038–AD83, may be sent by
any of the following methods:
• Agency Web site, via its Comments
Online process: https://
comments.cftc.gov. Follow the
instructions for submitting comments
through the Web site.
• Mail: David A. Stawick, Secretary of
the Commission, Commodity Futures
SUMMARY:
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Trading Commission, Three Lafayette
Centre, 1155 21st Street NW.,
Washington, DC 20581.
• Hand Delivery/Courier: Same as
mail above.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
FOR FURTHER INFORMATION CONTACT:
Adedayo Banwo, Counsel, Office of the
General Counsel, at (202) 418.6249,
abanwo@cftc.gov; With respect to
questions relating to international
consultation and coordination:
Jacqueline Mesa, Director, Office of
International Affairs, at (202) 418.5386,
jmesa@cftc.gov, Commodity Futures
Trading Commission, Three Lafayette
Centre, 1155 21st Street NW.,
Washington, DC 20581.
All comments must be submitted in
English, or if not, accompanied by an
English translation. Comments will be
posted as received to https://
www.cftc.gov. You should submit only
information that you wish to make
available publicly. If you wish the
Commission to consider information
that may be exempt from disclosure
under the Freedom of Information Act
(‘‘FOIA’’),1 a petition for confidential
treatment of the exempt information
may be submitted according to the
procedures established in § 145.9 of the
CFTC’s regulations.2 The Commission
reserves the right, but shall have no
obligation, to review, prescreen, filter,
redact, refuse, or remove any or all of
your submission from https://
www.cftc.gov that it may deem to be
inappropriate for publication, such as
obscene language. All submissions that
have been redacted or removed that
contain comments on the merits of the
rulemaking will be retained in the
public comment file and will be
considered as required under the
Administrative Procedure Act and other
applicable laws, and may be accessible
under FOIA.
In this
release, the Commission addresses
issues raised by foreign regulators with
respect to the scope and application of
the confidentiality and indemnification
provisions of new section 21(d) of the
CEA and proposes to clarify that these
provisions should not operate to inhibit
or prevent foreign regulatory authorities
from accessing data in which they have
an independent and sufficient
regulatory interest.
srobinson on DSK4SPTVN1PROD with PROPOSALS
SUPPLEMENTARY INFORMATION:
15
U.S.C. 552.
CFR 145.9.
2 17
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I. Background: Statutory and
Regulatory Authorities
On July 21, 2010, President Obama
signed into law the Dodd-Frank Act.3
Title VIIamended the CEA to establish
a comprehensive new regulatory
framework for swaps and security-based
swaps.4 The legislation was enacted to
reduce risk, increase transparency and
promote market integrity within the
financial system by, among other things:
(1) Providing for the registration and
comprehensive regulation of swap
dealers and major swap participants; (2)
imposing clearing and trade execution
requirements on standardized derivative
products; (3) creating robust
recordkeeping and real-time reporting
regimes; and (4) enhancing the
Commission’s rulemaking and
enforcement authorities with respect to,
among others, all registered entities and
intermediaries subject to the
Commission’s oversight.
To enhance transparency, promote
standardization and reduce systemic
risk, section 727 of the Dodd-Frank Act
added to the CEA new section
2(a)(13)(G),5 which requires all swaps—
whether cleared or uncleared—to be
reported to swap data repositories
(‘‘SDRs’’).SDRs are new registered
entities created by section 728 of the
Dodd-Frank Act.6 SDRs are required to
perform specified functions related to
the collection and maintenance of swap
transaction data and information.7
CEA section 21(c)(7) requires that
SDRs make data available to certain
domestic and foreign regulators 8 under
3 See Dodd-Frank Wall Street Reform and
Consumer Protection Act, Pub. L. 111–203, 124
Stat. 1376 (2010), available at https://www.cftc.gov/
LawRegulation/OTCDERIVATIVES/index.htm.
4 Pursuant to section 701 of the Dodd-Frank Act,
Title VII may be cited as the ‘‘Wall Street
Transparency and Accountability Act of 2010;’’
7 U.S.C. 1 et seq.
5 7 U.S.C. 2(a)(13)(G).
6 Section 721 of the Dodd-Frank Act amends
section 1a of the CEA to add a definition of the term
‘‘swap data repository.’’ Pursuant to CEA section
1a(48), the term ‘‘swap data repository means any
person that collects and maintains information or
records with respect to transactions or positions in,
or the terms and conditions of, swaps entered into
by third parties for the purpose of providing a
centralized recordkeeping facility for swaps.’’
7 U.S.C. 1a(48).
7 See 7 U.S.C. 24a(c). See also Commission, Final
Rulemaking: Swap Data Recordkeeping and
Reporting Requirements, 77 FR 2136, Jan. 13, 2012
(‘‘Data Final Rules’’). The Data Final Rules, among
other things, set forth regulations governing SDR
data collection and reporting responsibilities under
part 45 of the Commission’s regulations.
8 The Commission’s regulations designate such
regulators as either an ‘‘Appropriate Domestic
Regulator’’ or an ‘‘Appropriate Foreign Regulator’’
in § 49.17(b). See Commission, Final Rulemaking:
Swap Data Repositories: Registration Standards,
Duties and Core Principles, 76 FR 54538, 54554
Sept. 1, 2011 (‘‘SDR Final Rules’’).
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specified circumstances.9 Separately,
section 21(d) mandates that prior to
receipt of any requested data or
information from an SDR, a regulatory
authority described in section 21(c)(7)
shall agree in writing to abide by the
confidentiality requirements described
in section 8 of the CEA,10 and to
indemnify the SDR and the Commission
for any expenses arising from litigation
relating to the information provided
under section 8 of the CEA.11
Section 752 of the Dodd-Frank Act
seeks to ‘‘promote effective and
consistent global regulation of swaps,’’
and provides that the CFTC and foreign
regulators ‘‘may agree to such
information-sharing arrangements as
may be deemed to be necessary or
appropriate in the public interest.
* * *’’ 12 In light of this statutory
directive, the Commission has been
working to provide sufficient access to
SDR data to appropriate domestic and
foreign regulatory authorities.
On June 8, 2011, the Chairman of the
CFTC and the Chairman of the
Securities and Exchange Commission
(‘‘Chairmen’’) jointly submitted a letter
to Michel Barnier, European
Commissioner for Internal Markets and
Services,13 highlighting their desire for
international cooperation. In the letter,
the Chairmen expressed their belief that
indemnification and notice
requirements need not apply when a
registered SDR is also registered in a
foreign jurisdiction and the foreign
regulator, acting within the scope of its
jurisdiction, seeks information directly
from the SDR.
On September 1, 2011, the
Commission adopted regulations
implementing CEA section 21’s
registration standards, duties, and core
principles for SDRs. To implement the
provisions of section 21(c)(7) and (d),
the Commission adopted definitions
and standards for determining access by
domestic and foreign regulators to data
maintained by SDRs.
The Commission acknowledged in the
SDR Final Rules that the CEA’s
indemnification requirement could have
the unintended effect of inhibiting
direct access by other regulators to data
maintained by SDRsdue to various
home country laws and regulations.14
The SDR Final Rulesprovided that
97
U.S.C. 24a(c)(7).
U.S.C. 12.
11 7 U.S.C. 24a(d).
12 See section 752(a) of the Dodd-Frank Act.
13 See letter from Gary Gensler, Chairman of the
Commission, and Mary Schapiro, Chairman of the
SEC, to Michel Barnier, European Commissioner for
Internal Markets and Services, European
Commission, dated June 8, 2011.
14 See SDR Final Rules at 54554.
10 7
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under specified circumstances, certain
‘‘Appropriate Domestic Regulators’’ 15
may gain access to the swap data
reported and maintained by SDRs
without being subject to the notice and
indemnification requirements of CEA
sections 21(c)(7) and (d).16 In
connection with foreign regulatory
authorities, the Commission determined
in the SDR Final Rules that confidential
swap data reported to and maintained
by an SDR may be accessed by an
Appropriate Foreign Regulator 17
without the execution of a
confidentiality and indemnification
agreement when the Appropriate
Foreign Regulator has supervisory
authority over an SDR registered with it
pursuant to foreign law and/or
regulation that is also registered with
the Commission.
The confidentiality and
indemnification provisions of new CEA
section 21 apply only when a regulatory
authority seeks access to data from an
SDR. In the SDR Final Rules, the
Commission noted that section 8(e) of
the CEA provides for the Commission
(as opposed to an SDR) to share
confidential information in its
possession with any department or
agency of the Government of the United
States, or with any foreign futures
authority, department or agency of any
foreign government or political
subdivision thereof,18 acting within the
scope of its jurisdiction.19
15 The term Appropriate Domestic Regulator is
defined in 17 CFR 49.17(b)(1) as the Securities and
Exchange Commission; each prudential regulator
identified in section 1a(39) of the CEA. 7 U.S.C.
1a(39); the financial Stability Oversight Council; the
Department of Justice; any Federal Reserve Bank;
the Office of Financial Research; and any other
person the Commission deems appropriate.
16 In the Commission’s view, it is appropriate to
permit access to the swap data maintained by SDRs
to Appropriate Domestic Regulators that have
concurrent regulatory jurisdiction over such SDRs,
without the application of the notice and
indemnification provisions of sections 21(c)(7) and
(d) of the CEA. See SDR Final Rules at 54554 n.163.
Accordingly, these provisions do not apply to an
Appropriate Domestic Regulator that has regulatory
jurisdiction over an SDR registered with it pursuant
to a separate statutory authority that is also
registered with the Commission, if the Appropriate
Domestic Regulator executes an MOU or similar
information sharing arrangement with the
Commission and the Commission, consistent with
CEA section 21(c)(4)(A), designates the Appropriate
Domestic Regulator to receive direct electronic
access. See 17 CFR 17(d)(2).
17 The term Appropriate Foreign Regulator is
defined in 17 CFR 49.17(b)(2) as a foreign regulator
with an existing memorandum of understanding
(‘‘MOU’’) or similar type of information sharing
arrangement executed with the Commission, and/or
a foreign regulator without an MOU as determined
on a case-by-case basis by the Commission.
18 Section 725(f) of the Dodd-Frank Act amended
section 8(e) of the CEA to include foreign central
banks and ministries.
19 See SDR Final Rules at 54554.
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The SDR Final Rules became effective
on October 31, 2011.20 Under these
rules, trade repositories may apply to
the Commission for full registration as
SDRs.Pending the adoption and
effectiveness of other, related regulatory
provisions and definitions, however,
such registrations are deemed
‘‘provisional.’’ 21
II. Considerations Relevant to the
Commission’s Proposed Interpretative
Statement 22
A. International Considerations
As noted above, section 752(a) of the
Dodd-Frank Act directs the Commission
to consult and coordinate with foreign
regulatory authorities regarding the
establishment of consistent
international standards for the
regulation of swaps and various ‘‘swap
entities.’’ Section 752(a) also provides
that the Commission ‘‘may agree to such
information-sharing arrangements [with
foreign regulatory authorities] as may be
deemed to be necessary or appropriate
in the public interest’’ or for the
protection of investors and
counterparties.23
The Commission is committed to a
cooperative international approach to
the registration and regulation of SDRs,
and consulted extensively with various
foreign regulatory authorities in
promulgating both its proposed and
final regulations concerning SDRs.24
The Commission notes that the SDR
Final Rules are largely consistent with
the recommendations and goals of the
May 2010 ‘‘CPSS–IOSCO Consultative
Report, Considerations for Trade
Repositories in the OTC Derivatives
Market’’ (‘‘Working Group Report’’).25
20 Id.
21 See
17 CFR 49.3(b).
has been introduced in Congress
that would amend the CEA to eliminate or
substantially limit the SDR indemnification
provision.
23 See section 752(a) of the Dodd-Frank Act.
24 See public comment file in response to the
proposal for the SDR Final Rules, available at
https://comments.cftc.gov/PublicComments/
CommentList.aspx?id=939 and SDR Final Rules
note 6 at 54539, supra.
25 This working group was jointly established by
the Committee on Payment and Settlement Systems
(‘‘CPSS’’) of the Bank of International Settlements
and the Technical Committee of the International
Organization of Securities Commissions (‘‘IOSCO’’).
The Working Group Report presented a set of
factors to consider in connection with the design,
operation and regulation of SDRs. A significant
focus of the Working Group Report is access to SDR
data by appropriate regulators. The Working Group
Report urges that a trade repository ‘‘should support
market transparency by making data available to
relevant authorities and the public in line with their
respective information needs.’’ The Working Group
Report is available at https://www.bis.org/publ/
cpss90.pdf. See also CPSS–IOSCO Consultative
Report, Principles of Financial Market
22 Legislation
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B. Public Comments on SDR Regulations
In developing the SDR Final Rules,
the Commission received several
comments regarding access to SDR data
by foreign regulatory authorities and the
confidentiality and indemnification
provisions of CEA section 21(d). The
Commission has considered these
comments in formulating this proposed
interpretation but requests further
comment concerning the specific
interpretative statement proposed.
Managed Funds Association (‘‘MFA’’)
requested that the Commission actively
participate in facilitating foreign
regulatory access and confirming a
foreign regulator’s authority in
connection with any SDR data request.26
The CME Group Inc. (‘‘CME’’) argued
against the Commission designating any
third party to receive swap data, and
TriOptima suggested that the
Commission ‘‘adopt as flexible an
interpretation as possible’’ regarding the
indemnification provisions in CEA
section 21(d).27
The Depository Trust & Clearing
Corporation (‘‘DTCC’’) stated that the
‘‘indemnification provisions should not
apply in situations where regulators are
carrying out regulatory responsibilities,
acting in a manner consistent with
international agreements and
maintaining the confidentiality of
data.’’ 28 Additionally, the Commission
received a comment letter from the
European Securities and Markets
Authority (‘‘ESMA’’) 29 stating that it
believes the indemnification provision
‘‘undermines’’ principles of trust and
consultation.
C. Consultations With Foreign
Regulatory Authorities
Consistent with the international
harmonization envisioned by section
752 of the Dodd-Frank Act, the
Commission has engaged in
consultations with foreign regulatory
authorities regarding the Commission’s
regulations relating to the Dodd-Frank
Act. During these consultations, many
foreign regulatory authorities have
expressed concern about the difficulty
in complying with the indemnification
provisions of CEA section 21(d).
As a consequence of these
consultations with foreign regulatory
Infrastructures (March 2011) available at https://
www.bis.org/publ/cpss94.pdf. See also Financial
Stability Board (‘‘FSB’’), Implementing OTC
Derivatives Market Reforms, Oct. 25, 2010 (‘‘FSB
Report’’); FSB, Derivative Market Reforms, Progress
Report on Implementation, Apr. 15, 2010 (‘‘FSB
Progress Report’’).
26 See comment letter from MFA.
27 See comment letters from CME and TriOptima.
28 See comment letter from DTCC.
29 See comment letter from ESMA.
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authorities, and pursuant to the
mandate for cooperation under section
752, the Commission concludes that
further guidance is necessary to ensure
that appropriate access by foreign
regulatory authorities is not
unnecessarily inhibited. For example,
the Commission has learned that foreign
regulatory authorities have asked
whether a recognition regime with
respect to SDRs, and/or access by
foreign authorities that do not regulate
an SDR, would conflict with
§ 49.17(d)(3) and § 49.18(c) of the SDR
Final Rules, which refer to registration
with Appropriate Foreign Regulators.
Foreign regulatory authorities have also
taken action to harmonize regulatory
reporting rules.
While the SDR Final Rules address
foreign regulators with supervisory
authority and regulatory responsibility,
the Commission is proposing the
following interpretative statement,
pursuant to section 752, to ensure that
foreign regulators receive sufficient
access to data reported to SDRs where
such foreign regulators have an
independent and sufficient regulatory
interest.
srobinson on DSK4SPTVN1PROD with PROPOSALS
III. Commission Proposed
Interpretative Statement
In this proposed interpretative
statement, the CFTC provides guidance
regarding the confidentiality and
indemnification provisions of CEA
section 21(d). As noted above, the
Commission seeks comment from
interested members of the public on all
aspects of this proposed interpretative
statement.
A. Data Reported to Registered SDRs
The Commission understands that
some registered SDRs also maybe
registered, recognized or otherwise
authorized in a foreign jurisdiction and
may accept swap data reported pursuant
to the foreign regulatory regime. The
Commission concludes that the
confidentiality and indemnification
provisions of CEA section 21(d)
generally apply only to such data
reported pursuant to the CEA and
Commission regulations.
The Commission further concludes
that the confidentiality and
indemnification provisions should not
operate to inhibit or prevent foreign
regulatory authorities from accessing
data in which they have an independent
and sufficient regulatory interest (even
if that data also has been reported
pursuant to the CEA and Commission
regulations).
Accordingly, and consistent with the
Commission’s SDR Final Rules, the
Commission proposes to interpret CEA
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section 21(d) such that a registered SDR
would not be subject to the
confidentiality and indemnification
provisions of that section if:
• Such registered SDR also is
registered, recognized or otherwise
authorized in a foreign jurisdiction’s
regulatory regime; and
• The data sought to be accessed by
a foreign regulatory authority has been
reported to such registered SDR
pursuant to the foreign jurisdiction’s
regulatory regime.
This proposed interpretative guidance
is grounded in principles of
international law and comity. For
example, in F. Hoffmann-La Roche Ltd.
v. Empagran S.A., the U.S. Supreme
Court, in reviewing the extraterritorial
applicability of a different federal
statute, stated that extraterritorial
jurisdiction should be construed, where
ambiguous, ‘‘to avoid unreasonable
interference with the sovereign
authority of other nations.’’ 30 In cases
considering concepts of international
law and comity in evaluating the
extraterritorial scope of federal statutes,
the Supreme Court has noted that the
principles in the Third Restatement of
Foreign Relations Law are relevant to
the interpretation of U.S. law.31
Specifically, section 403 of the Third
Restatement of Foreign Relations Law
states, in relevant part:
Whether exercise of jurisdiction over a
person or activity is unreasonable is
determined by evaluating all relevant factors,
including, where appropriate:
(a) The link of the activity to the territory
of the regulating state, i.e., the extent to
which the activity takes place within the
territory, or has substantial, direct, and
foreseeable effect upon or in the territory;
(b) The connections, such as nationality,
residence, or economic activity, between the
regulating state and the person principally
responsible for the activity to be regulated, or
between that state and those whom the
regulation is designed to protect;
(c) The character of the activity to be
regulated, the importance of regulation to the
regulating state, the extent to which other
states regulate such activities, and the degree
to which the desirability of such regulation
is generally accepted;
(d) The existence of justified expectations
that might be protected or hurt by the
regulation;
(e) The importance of the regulation to the
international political, legal, or economic
system;
(f) The extent to which the regulation is
consistent with the traditions of the
international system;
30 F. Hoffmann-LaRoche, Ltd. v. Empagran S.A.,
542 U.S. 155, 164 (2004). In Hoffmann-LaRoche, the
Supreme Court also stated that canons of statutory
construction ‘‘assume that legislators take account
of the legitimate sovereign interests of other nations
when they write American laws.’’ Id.
31 Id. at 164–165.
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(g) The extent to which another state may
have an interest in regulating the activity;
and
(h) The likelihood of conflict with
regulation by another state.32
To avoid unreasonable interference
with the sovereign authority of foreign
regulators, this proposed interpretative
statement is supported and
underpinned by principles of
international law and comity.
B. Foreign Regulatory Access
In the Commission’s view, a foreign
regulator’s access to data held in a
registered SDR that also is registered,
recognized, or otherwise authorized in a
foreign jurisdiction’s regulatory regime,
where the data sought to be accessed
has been reported pursuant to that
regulatory regime, should be governed
by such foreign jurisdiction’s regulatory
regime. The Commission concludes that
application of the requirements of CEA
section 21(d) in these circumstances is
unreasonable in light of, among other
things, the importance of such data to
the foreign jurisdiction’s regulatory
regime, foreign regulators’ interest in
unfettered access to such data, and the
traditions of mutual trust and
cooperation among international
regulators.33
Therefore, the Commission proposes
that a foreign regulator’s access to data
from a registered SDR that also is
registered, recognized, or otherwise
authorized in a foreign jurisdiction’s
regulatory regime, where the data to be
accessed has been reported pursuant to
that regulatory regime, will be dictated
by that foreign jurisdiction’s regulatory
regime and not by the CEA or
Commission regulations. Such access is
appropriate, in the Commission’s view,
even if the applicable data is also
reported to the registered SDR pursuant
to the Commission’s Data Final Rules.34
32 Rest. 3d., Third Restatement Foreign Relations
Law section 403 (scope of a statutory grant of
authority must be construed in the context of
international law and comity including, as
appropriate, the extent to which regulation is
consistent with the traditions of the international
system).
33 The Commission notes that access to data held
by trade repositories is a concept under discussion
and development among international regulators.
At the request of the FSB, CPSS and IOSCO have
established a working group of relevant authorities
to produce a forthcoming report regarding
authorities’ access to trade repository data.
34 Regarding the Commission’s access to SDR
data, section 21(b)(1)(A) of the CEA states that the
Commission ‘‘shall prescribe standards that specify
the data elements for each swap that shall be
collected and maintained by each registered swap
data repository.’’ Section 21(c)(1) of the CEA
requires registered SDRs to ‘‘accept data prescribed
by the Commission for each swap under subsection
(b).’’ Therefore, with respect to Commission access
to data held in registered SDRs, the Commission
E:\FR\FM\07MYP1.SGM
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Federal Register / Vol. 77, No. 88 / Monday, May 7, 2012 / Proposed Rules
Additionally, the Commission
reiterates that a foreign regulatory
authority, like domestic regulators, can
nonetheless receive confidential data,
without the execution of a
confidentiality and indemnification
agreement, from the Commission (as
opposed to an SDR) pursuant to section
8(e) of the CEA.35 Such data sharing and
access would be governed by the
confidentiality provisions of section 8 of
the CEA.
C. Request for Comment
The Commission requests comment
on all aspects of its proposed
interpretative statement. In particular,
the Commission requests comment on
the following issue: How would the
timing and implementation of foreign
jurisdictions’ regulatory regimes affect
the Commission’s proposed
interpretative guidance?
By the Commission.
Dated: Issued in Washington, DC, on April
30, 2012.
David A. Stawick,
Secretary of the Commission.
Appendices To Swap Data Repositories:
Interpretative Statement Regarding the
Confidentiality and Indemnification
Provisions of Section 21(d) of the
Commodity Exchange Act Interpretive
Statement—Commission Voting
Summary and Statements of
Commissioners
Note: The following appendices will not
appear in the Code of Federal Regulations.
Appendix 1—Commission Voting
Summary
srobinson on DSK4SPTVN1PROD with PROPOSALS
On this matter, Chairman Gensler and
Commissioners Sommers, Chilton, O’Malia
and Wetjen voted in the affirmative; no
Commissioner votes in the negative.
concludes that the direct electronic access
provisions of CEA section 21(c)(4) apply only to
such data that the SDR is required to accept under
section 21(c)(1), which is further defined by part 45
of the Commission’s regulations. In this respect, the
Commission concludes that its direct electronic
access applies only to such data reported pursuant
to section 21 and Commission regulations
promulgated thereunder.
35 As noted above, CEA section 8(e) allows the
Commission to share confidential information in its
possession obtained in connection with the
administration of the CEA with ‘‘any department or
agency of the Government of the United States’’ or
with any foreign futures authority or a department,
central bank or ministry, or agency of a foreign
government or political subdivision thereof, acting
within the scope of its jurisdiction. The
Commission acknowledges the difficulty that
registered SDRs may face in determining what data
or reporting falls within the jurisdiction of a
regulatory authority. In this regard, the Commission
is considering a separate release regarding section
2(i) of the CEA.
VerDate Mar<15>2010
17:41 May 04, 2012
Jkt 226001
Appendix 2—Statement of Chairman
Gary Gensler
I support the proposed interpretative
statement regarding the application of the
Dodd-Frank Wall Street Reform and
Consumer Protection Act (Dodd-Frank Act)
indemnification provisions for swap data
repositories (SDRs). The Commission is
working closely with international regulators
on a collaborative approach regarding how
data may be accessed by regulators. The
proposed guidance, which benefited from
international input, states the Commission’s
view that foreign regulators will not be
subject to the indemnification provisions in
the Dodd-Frank Act if the SDR is registered,
recognized or otherwise authorized by
foreign law and the data to be accessed is
reported to the SDR pursuant to foreign law.
The public will now have an opportunity to
comment on the proposed guidance, and I
look forward to the public’s input.
Appendix 3—Statement of
Commissioner Jill E. Sommers
I concur in the issuance of this Proposed
Interpretative Statement Regarding the
Confidentiality and Indemnification
Provisions of Section 21(d) of the Commodity
Exchange Act (Proposed Interpretive
Statement). It provides some additional
clarification with respect to how the
Commission intends to interpret the
application of the Section 21(d)
indemnification provisions beyond what the
Commission stated when it finalized the
swap data repository (SDR) rules. See Swap
Data Repositories: Registration Standards,
Duties and Core Principles, 76 FR 54,538
(Sept. 1, 2011). However, a legislative fix is
the only real solution to providing
appropriate regulators, both foreign and
domestic, with timely access to relevant data.
I agree with Commissioner O’Malia that the
Commission should publicly support repeal
of the indemnification provisions, and note
that the SEC has already done so.
When finalizing the SDR rules, the
Commission stated that a foreign regulator
may have direct access to confidential swap
data reported to and maintained by an SDR
registered with the Commission without
executing a Confidentiality and
Indemnification Agreement when the SDR is
also registered with the foreign regulator and
the foreign regulator is acting in a regulatory
capacity with respect to the SDR. See id. at
54,554. The Proposed Guidance clarifies that
this should be the case even if the data the
foreign regulator seeks also has been reported
pursuant to the CEA and Commission
regulations.
Aside from making this point, the
Proposed Interpretive Statement does not
provide any information that cannot be
otherwise gleaned from the SDR final rules,
with one notable exception. The final SDR
rules define an ‘‘Appropriate Foreign
Regulator’’ as one that has supervisory
authority over an SDR that is registered with
the foreign regulator and with the CFTC. The
Proposed Interpretive Statement expands this
concept to SDRs that are registered,
recognized, or otherwise authorized in a
foreign jurisdiction’s regulatory regime.
PO 00000
Frm 00008
Fmt 4702
Sfmt 9990
26713
Thus, registration and recognition are
equivalent. This is a welcome clarification
and a step in the right direction.
I should note that the indemnification
provisions of Section 21(d) may have an
adverse effect on U.S. regulators too. The
Proposed Interpretive Statement touches on a
distinction drawn in Part 49 between
‘‘Appropriate Domestic Regulators,’’ which
include a number of domestic regulatory
authorities, and an ‘‘Appropriate Domestic
Regulator with Regulatory Responsibility
over a Swap Data Repository’’ (a single entity
subcategory of Appropriate Domestic
Regulators, namely, the Securities and
Exchange Commission (SEC)). Only the latter
category of domestic regulator (i.e. the SEC)
is exempt from the indemnification
provisions of Section 21(d). While it makes
sense that the SEC should be able to receive
SDR data directly from an SDR absent an
indemnification agreement, I encourage
comments as to whether other Appropriate
Domestic Regulators should have similar
access.
Appendix 4—Statement of
Commissioner Scott D. O’Malia
I concur in support of the Commission’s
proposed interpretative statement (‘‘Proposed
Interpretative Statement’’) regarding the
confidentiality and indemnification
provisions of Section 21(d) of the Commodity
Exchange Act (‘‘CEA’’).
Ultimately, Congress should repeal the
confidentiality and indemnification
provisions of Section 21(d) of the CEA and
the Commission should publicly support that
repeal. Absent a legislative fix, however, I
believe the Commission is taking the right
step to allay the concerns expressed by many
foreign regulatory authorities.
I am somewhat concerned that the
Proposed Interpretative Statement does not
address one important issue. Specifically, the
Proposed Interpretative Statement would not
provide foreign regulatory authorities with
access to swaps data if those authorities had
not yet finalized their regulations. In order to
better understand the public’s view on this
issue, I have added a question seeking
comment on how the timing and
implementation of foreign jurisdictions’
regulatory regimes should affect the
Commission’s final interpretation.
Lastly, I am pleased that this Proposed
Interpretative Statement is based on
principles of international harmonization
and comity. The Commission should
continue to consult with foreign regulatory
authorities in a manner consistent with
international agreements regarding the
registration of swap data repositories and the
sharing of swaps data. In my view, these
principles should establish the foundation of
the Commission’s forthcoming rulemaking
concerning the extraterritorial application of
the Dodd-Frank Act to foreign-based entities.
Several foreign jurisdictions are in the
process of finalizing new rules for the
regulation of swaps and it is important that
those rules provide a level and competitive
playing field for U.S. firms as well.
[FR Doc. 2012–10918 Filed 5–4–12; 8:45 am]
BILLING CODE 6351–01–P
E:\FR\FM\07MYP1.SGM
07MYP1
Agencies
[Federal Register Volume 77, Number 88 (Monday, May 7, 2012)]
[Proposed Rules]
[Pages 26709-26713]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-10918]
=======================================================================
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COMMODITY FUTURES TRADING COMMISSION
17 CFR Part 49
RIN 3038-AD83
Swap Data Repositories: Interpretative Statement Regarding the
Confidentiality and Indemnification Provisions of Section 21(d) of the
Commodity Exchange Act
AGENCY: Commodity Futures Trading Commission.
ACTION: Proposed interpretative statement.
-----------------------------------------------------------------------
SUMMARY: The Commodity Futures Trading Commission (``Commission'' or
``CFTC'') is proposing this interpretative statement to provide
guidance regarding the applicability of the confidentiality and
indemnification provisions set forth in new section 21(d) of the
Commodity Exchange Act (``CEA'') added by section 728 of the Dodd-Frank
Wall Street Reform and Consumer Protection Act (``Dodd-Frank Act'').
The Commission requests comment on all aspects of the proposed
interpretative statement. The proposed interpretative statement
clarifies that the provisions of section 21(d) should not operate to
inhibit or prevent foreign regulatory authorities from accessing data
in which they have an independent and sufficient regulatory interest,
even if that data also has been reported pursuant to the CEA and
Commission regulations.
DATES: Comments must be received on or before June 6, 2012.
ADDRESSES: Comments, identified by RIN number 3038-AD83, may be sent by
any of the following methods:
Agency Web site, via its Comments Online process: https://comments.cftc.gov. Follow the instructions for submitting comments
through the Web site.
Mail: David A. Stawick, Secretary of the Commission,
Commodity Futures
[[Page 26710]]
Trading Commission, Three Lafayette Centre, 1155 21st Street NW.,
Washington, DC 20581.
Hand Delivery/Courier: Same as mail above.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
FOR FURTHER INFORMATION CONTACT: Adedayo Banwo, Counsel, Office of the
General Counsel, at (202) 418.6249, abanwo@cftc.gov; With respect to
questions relating to international consultation and coordination:
Jacqueline Mesa, Director, Office of International Affairs, at (202)
418.5386, jmesa@cftc.gov, Commodity Futures Trading Commission, Three
Lafayette Centre, 1155 21st Street NW., Washington, DC 20581.
All comments must be submitted in English, or if not, accompanied
by an English translation. Comments will be posted as received to
https://www.cftc.gov. You should submit only information that you wish
to make available publicly. If you wish the Commission to consider
information that may be exempt from disclosure under the Freedom of
Information Act (``FOIA''),\1\ a petition for confidential treatment of
the exempt information may be submitted according to the procedures
established in Sec. 145.9 of the CFTC's regulations.\2\ The Commission
reserves the right, but shall have no obligation, to review, prescreen,
filter, redact, refuse, or remove any or all of your submission from
https://www.cftc.gov that it may deem to be inappropriate for
publication, such as obscene language. All submissions that have been
redacted or removed that contain comments on the merits of the
rulemaking will be retained in the public comment file and will be
considered as required under the Administrative Procedure Act and other
applicable laws, and may be accessible under FOIA.
---------------------------------------------------------------------------
\1\ 5 U.S.C. 552.
\2\ 17 CFR 145.9.
SUPPLEMENTARY INFORMATION: In this release, the Commission addresses
issues raised by foreign regulators with respect to the scope and
application of the confidentiality and indemnification provisions of
new section 21(d) of the CEA and proposes to clarify that these
provisions should not operate to inhibit or prevent foreign regulatory
authorities from accessing data in which they have an independent and
sufficient regulatory interest.
I. Background: Statutory and Regulatory Authorities
On July 21, 2010, President Obama signed into law the Dodd-Frank
Act.\3\ Title VIIamended the CEA to establish a comprehensive new
regulatory framework for swaps and security-based swaps.\4\ The
legislation was enacted to reduce risk, increase transparency and
promote market integrity within the financial system by, among other
things: (1) Providing for the registration and comprehensive regulation
of swap dealers and major swap participants; (2) imposing clearing and
trade execution requirements on standardized derivative products; (3)
creating robust recordkeeping and real-time reporting regimes; and (4)
enhancing the Commission's rulemaking and enforcement authorities with
respect to, among others, all registered entities and intermediaries
subject to the Commission's oversight.
---------------------------------------------------------------------------
\3\ See Dodd-Frank Wall Street Reform and Consumer Protection
Act, Pub. L. 111-203, 124 Stat. 1376 (2010), available at https://www.cftc.gov/LawRegulation/OTCDERIVATIVES/index.htm.
\4\ Pursuant to section 701 of the Dodd-Frank Act, Title VII may
be cited as the ``Wall Street Transparency and Accountability Act of
2010;'' 7 U.S.C. 1 et seq.
---------------------------------------------------------------------------
To enhance transparency, promote standardization and reduce
systemic risk, section 727 of the Dodd-Frank Act added to the CEA new
section 2(a)(13)(G),\5\ which requires all swaps--whether cleared or
uncleared--to be reported to swap data repositories (``SDRs'').SDRs are
new registered entities created by section 728 of the Dodd-Frank
Act.\6\ SDRs are required to perform specified functions related to the
collection and maintenance of swap transaction data and information.\7\
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\5\ 7 U.S.C. 2(a)(13)(G).
\6\ Section 721 of the Dodd-Frank Act amends section 1a of the
CEA to add a definition of the term ``swap data repository.''
Pursuant to CEA section 1a(48), the term ``swap data repository
means any person that collects and maintains information or records
with respect to transactions or positions in, or the terms and
conditions of, swaps entered into by third parties for the purpose
of providing a centralized recordkeeping facility for swaps.'' 7
U.S.C. 1a(48).
\7\ See 7 U.S.C. 24a(c). See also Commission, Final Rulemaking:
Swap Data Recordkeeping and Reporting Requirements, 77 FR 2136, Jan.
13, 2012 (``Data Final Rules''). The Data Final Rules, among other
things, set forth regulations governing SDR data collection and
reporting responsibilities under part 45 of the Commission's
regulations.
---------------------------------------------------------------------------
CEA section 21(c)(7) requires that SDRs make data available to
certain domestic and foreign regulators \8\ under specified
circumstances.\9\ Separately, section 21(d) mandates that prior to
receipt of any requested data or information from an SDR, a regulatory
authority described in section 21(c)(7) shall agree in writing to abide
by the confidentiality requirements described in section 8 of the
CEA,\10\ and to indemnify the SDR and the Commission for any expenses
arising from litigation relating to the information provided under
section 8 of the CEA.\11\
---------------------------------------------------------------------------
\8\ The Commission's regulations designate such regulators as
either an ``Appropriate Domestic Regulator'' or an ``Appropriate
Foreign Regulator'' in Sec. 49.17(b). See Commission, Final
Rulemaking: Swap Data Repositories: Registration Standards, Duties
and Core Principles, 76 FR 54538, 54554 Sept. 1, 2011 (``SDR Final
Rules'').
\9\ 7 U.S.C. 24a(c)(7).
\10\ 7 U.S.C. 12.
\11\ 7 U.S.C. 24a(d).
---------------------------------------------------------------------------
Section 752 of the Dodd-Frank Act seeks to ``promote effective and
consistent global regulation of swaps,'' and provides that the CFTC and
foreign regulators ``may agree to such information-sharing arrangements
as may be deemed to be necessary or appropriate in the public interest.
* * *'' \12\ In light of this statutory directive, the Commission has
been working to provide sufficient access to SDR data to appropriate
domestic and foreign regulatory authorities.
---------------------------------------------------------------------------
\12\ See section 752(a) of the Dodd-Frank Act.
---------------------------------------------------------------------------
On June 8, 2011, the Chairman of the CFTC and the Chairman of the
Securities and Exchange Commission (``Chairmen'') jointly submitted a
letter to Michel Barnier, European Commissioner for Internal Markets
and Services,\13\ highlighting their desire for international
cooperation. In the letter, the Chairmen expressed their belief that
indemnification and notice requirements need not apply when a
registered SDR is also registered in a foreign jurisdiction and the
foreign regulator, acting within the scope of its jurisdiction, seeks
information directly from the SDR.
---------------------------------------------------------------------------
\13\ See letter from Gary Gensler, Chairman of the Commission,
and Mary Schapiro, Chairman of the SEC, to Michel Barnier, European
Commissioner for Internal Markets and Services, European Commission,
dated June 8, 2011.
---------------------------------------------------------------------------
On September 1, 2011, the Commission adopted regulations
implementing CEA section 21's registration standards, duties, and core
principles for SDRs. To implement the provisions of section 21(c)(7)
and (d), the Commission adopted definitions and standards for
determining access by domestic and foreign regulators to data
maintained by SDRs.
The Commission acknowledged in the SDR Final Rules that the CEA's
indemnification requirement could have the unintended effect of
inhibiting direct access by other regulators to data maintained by
SDRsdue to various home country laws and regulations.\14\ The SDR Final
Rulesprovided that
[[Page 26711]]
under specified circumstances, certain ``Appropriate Domestic
Regulators'' \15\ may gain access to the swap data reported and
maintained by SDRs without being subject to the notice and
indemnification requirements of CEA sections 21(c)(7) and (d).\16\ In
connection with foreign regulatory authorities, the Commission
determined in the SDR Final Rules that confidential swap data reported
to and maintained by an SDR may be accessed by an Appropriate Foreign
Regulator \17\ without the execution of a confidentiality and
indemnification agreement when the Appropriate Foreign Regulator has
supervisory authority over an SDR registered with it pursuant to
foreign law and/or regulation that is also registered with the
Commission.
---------------------------------------------------------------------------
\14\ See SDR Final Rules at 54554.
\15\ The term Appropriate Domestic Regulator is defined in 17
CFR 49.17(b)(1) as the Securities and Exchange Commission; each
prudential regulator identified in section 1a(39) of the CEA. 7
U.S.C. 1a(39); the financial Stability Oversight Council; the
Department of Justice; any Federal Reserve Bank; the Office of
Financial Research; and any other person the Commission deems
appropriate.
\16\ In the Commission's view, it is appropriate to permit
access to the swap data maintained by SDRs to Appropriate Domestic
Regulators that have concurrent regulatory jurisdiction over such
SDRs, without the application of the notice and indemnification
provisions of sections 21(c)(7) and (d) of the CEA. See SDR Final
Rules at 54554 n.163. Accordingly, these provisions do not apply to
an Appropriate Domestic Regulator that has regulatory jurisdiction
over an SDR registered with it pursuant to a separate statutory
authority that is also registered with the Commission, if the
Appropriate Domestic Regulator executes an MOU or similar
information sharing arrangement with the Commission and the
Commission, consistent with CEA section 21(c)(4)(A), designates the
Appropriate Domestic Regulator to receive direct electronic access.
See 17 CFR 17(d)(2).
\17\ The term Appropriate Foreign Regulator is defined in 17 CFR
49.17(b)(2) as a foreign regulator with an existing memorandum of
understanding (``MOU'') or similar type of information sharing
arrangement executed with the Commission, and/or a foreign regulator
without an MOU as determined on a case-by-case basis by the
Commission.
---------------------------------------------------------------------------
The confidentiality and indemnification provisions of new CEA
section 21 apply only when a regulatory authority seeks access to data
from an SDR. In the SDR Final Rules, the Commission noted that section
8(e) of the CEA provides for the Commission (as opposed to an SDR) to
share confidential information in its possession with any department or
agency of the Government of the United States, or with any foreign
futures authority, department or agency of any foreign government or
political subdivision thereof,\18\ acting within the scope of its
jurisdiction.\19\
---------------------------------------------------------------------------
\18\ Section 725(f) of the Dodd-Frank Act amended section 8(e)
of the CEA to include foreign central banks and ministries.
\19\ See SDR Final Rules at 54554.
---------------------------------------------------------------------------
The SDR Final Rules became effective on October 31, 2011.\20\ Under
these rules, trade repositories may apply to the Commission for full
registration as SDRs.Pending the adoption and effectiveness of other,
related regulatory provisions and definitions, however, such
registrations are deemed ``provisional.'' \21\
---------------------------------------------------------------------------
\20\ Id.
\21\ See 17 CFR 49.3(b).
---------------------------------------------------------------------------
II. Considerations Relevant to the Commission's Proposed Interpretative
Statement \22\
---------------------------------------------------------------------------
\22\ Legislation has been introduced in Congress that would
amend the CEA to eliminate or substantially limit the SDR
indemnification provision.
---------------------------------------------------------------------------
A. International Considerations
As noted above, section 752(a) of the Dodd-Frank Act directs the
Commission to consult and coordinate with foreign regulatory
authorities regarding the establishment of consistent international
standards for the regulation of swaps and various ``swap entities.''
Section 752(a) also provides that the Commission ``may agree to such
information-sharing arrangements [with foreign regulatory authorities]
as may be deemed to be necessary or appropriate in the public
interest'' or for the protection of investors and counterparties.\23\
---------------------------------------------------------------------------
\23\ See section 752(a) of the Dodd-Frank Act.
---------------------------------------------------------------------------
The Commission is committed to a cooperative international approach
to the registration and regulation of SDRs, and consulted extensively
with various foreign regulatory authorities in promulgating both its
proposed and final regulations concerning SDRs.\24\ The Commission
notes that the SDR Final Rules are largely consistent with the
recommendations and goals of the May 2010 ``CPSS-IOSCO Consultative
Report, Considerations for Trade Repositories in the OTC Derivatives
Market'' (``Working Group Report'').\25\
---------------------------------------------------------------------------
\24\ See public comment file in response to the proposal for the
SDR Final Rules, available at https://comments.cftc.gov/PublicComments/CommentList.aspx?id=939 and SDR Final Rules note 6 at
54539, supra.
\25\ This working group was jointly established by the Committee
on Payment and Settlement Systems (``CPSS'') of the Bank of
International Settlements and the Technical Committee of the
International Organization of Securities Commissions (``IOSCO'').
The Working Group Report presented a set of factors to consider in
connection with the design, operation and regulation of SDRs. A
significant focus of the Working Group Report is access to SDR data
by appropriate regulators. The Working Group Report urges that a
trade repository ``should support market transparency by making data
available to relevant authorities and the public in line with their
respective information needs.'' The Working Group Report is
available at https://www.bis.org/publ/cpss90.pdf. See also CPSS-IOSCO
Consultative Report, Principles of Financial Market Infrastructures
(March 2011) available at https://www.bis.org/publ/cpss94.pdf. See
also Financial Stability Board (``FSB''), Implementing OTC
Derivatives Market Reforms, Oct. 25, 2010 (``FSB Report''); FSB,
Derivative Market Reforms, Progress Report on Implementation, Apr.
15, 2010 (``FSB Progress Report'').
---------------------------------------------------------------------------
B. Public Comments on SDR Regulations
In developing the SDR Final Rules, the Commission received several
comments regarding access to SDR data by foreign regulatory authorities
and the confidentiality and indemnification provisions of CEA section
21(d). The Commission has considered these comments in formulating this
proposed interpretation but requests further comment concerning the
specific interpretative statement proposed.
Managed Funds Association (``MFA'') requested that the Commission
actively participate in facilitating foreign regulatory access and
confirming a foreign regulator's authority in connection with any SDR
data request.\26\ The CME Group Inc. (``CME'') argued against the
Commission designating any third party to receive swap data, and
TriOptima suggested that the Commission ``adopt as flexible an
interpretation as possible'' regarding the indemnification provisions
in CEA section 21(d).\27\
---------------------------------------------------------------------------
\26\ See comment letter from MFA.
\27\ See comment letters from CME and TriOptima.
---------------------------------------------------------------------------
The Depository Trust & Clearing Corporation (``DTCC'') stated that
the ``indemnification provisions should not apply in situations where
regulators are carrying out regulatory responsibilities, acting in a
manner consistent with international agreements and maintaining the
confidentiality of data.'' \28\ Additionally, the Commission received a
comment letter from the European Securities and Markets Authority
(``ESMA'') \29\ stating that it believes the indemnification provision
``undermines'' principles of trust and consultation.
---------------------------------------------------------------------------
\28\ See comment letter from DTCC.
\29\ See comment letter from ESMA.
---------------------------------------------------------------------------
C. Consultations With Foreign Regulatory Authorities
Consistent with the international harmonization envisioned by
section 752 of the Dodd-Frank Act, the Commission has engaged in
consultations with foreign regulatory authorities regarding the
Commission's regulations relating to the Dodd-Frank Act. During these
consultations, many foreign regulatory authorities have expressed
concern about the difficulty in complying with the indemnification
provisions of CEA section 21(d).
As a consequence of these consultations with foreign regulatory
[[Page 26712]]
authorities, and pursuant to the mandate for cooperation under section
752, the Commission concludes that further guidance is necessary to
ensure that appropriate access by foreign regulatory authorities is not
unnecessarily inhibited. For example, the Commission has learned that
foreign regulatory authorities have asked whether a recognition regime
with respect to SDRs, and/or access by foreign authorities that do not
regulate an SDR, would conflict with Sec. 49.17(d)(3) and Sec.
49.18(c) of the SDR Final Rules, which refer to registration with
Appropriate Foreign Regulators. Foreign regulatory authorities have
also taken action to harmonize regulatory reporting rules.
While the SDR Final Rules address foreign regulators with
supervisory authority and regulatory responsibility, the Commission is
proposing the following interpretative statement, pursuant to section
752, to ensure that foreign regulators receive sufficient access to
data reported to SDRs where such foreign regulators have an independent
and sufficient regulatory interest.
III. Commission Proposed Interpretative Statement
In this proposed interpretative statement, the CFTC provides
guidance regarding the confidentiality and indemnification provisions
of CEA section 21(d). As noted above, the Commission seeks comment from
interested members of the public on all aspects of this proposed
interpretative statement.
A. Data Reported to Registered SDRs
The Commission understands that some registered SDRs also maybe
registered, recognized or otherwise authorized in a foreign
jurisdiction and may accept swap data reported pursuant to the foreign
regulatory regime. The Commission concludes that the confidentiality
and indemnification provisions of CEA section 21(d) generally apply
only to such data reported pursuant to the CEA and Commission
regulations.
The Commission further concludes that the confidentiality and
indemnification provisions should not operate to inhibit or prevent
foreign regulatory authorities from accessing data in which they have
an independent and sufficient regulatory interest (even if that data
also has been reported pursuant to the CEA and Commission regulations).
Accordingly, and consistent with the Commission's SDR Final Rules,
the Commission proposes to interpret CEA section 21(d) such that a
registered SDR would not be subject to the confidentiality and
indemnification provisions of that section if:
Such registered SDR also is registered, recognized or
otherwise authorized in a foreign jurisdiction's regulatory regime; and
The data sought to be accessed by a foreign regulatory
authority has been reported to such registered SDR pursuant to the
foreign jurisdiction's regulatory regime.
This proposed interpretative guidance is grounded in principles of
international law and comity. For example, in F. Hoffmann-La Roche Ltd.
v. Empagran S.A., the U.S. Supreme Court, in reviewing the
extraterritorial applicability of a different federal statute, stated
that extraterritorial jurisdiction should be construed, where
ambiguous, ``to avoid unreasonable interference with the sovereign
authority of other nations.'' \30\ In cases considering concepts of
international law and comity in evaluating the extraterritorial scope
of federal statutes, the Supreme Court has noted that the principles in
the Third Restatement of Foreign Relations Law are relevant to the
interpretation of U.S. law.\31\
---------------------------------------------------------------------------
\30\ F. Hoffmann-LaRoche, Ltd. v. Empagran S.A., 542 U.S. 155,
164 (2004). In Hoffmann-LaRoche, the Supreme Court also stated that
canons of statutory construction ``assume that legislators take
account of the legitimate sovereign interests of other nations when
they write American laws.'' Id.
\31\ Id. at 164-165.
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Specifically, section 403 of the Third Restatement of Foreign
Relations Law states, in relevant part:
Whether exercise of jurisdiction over a person or activity is
unreasonable is determined by evaluating all relevant factors,
including, where appropriate:
(a) The link of the activity to the territory of the regulating
state, i.e., the extent to which the activity takes place within the
territory, or has substantial, direct, and foreseeable effect upon
or in the territory;
(b) The connections, such as nationality, residence, or economic
activity, between the regulating state and the person principally
responsible for the activity to be regulated, or between that state
and those whom the regulation is designed to protect;
(c) The character of the activity to be regulated, the
importance of regulation to the regulating state, the extent to
which other states regulate such activities, and the degree to which
the desirability of such regulation is generally accepted;
(d) The existence of justified expectations that might be
protected or hurt by the regulation;
(e) The importance of the regulation to the international
political, legal, or economic system;
(f) The extent to which the regulation is consistent with the
traditions of the international system;
(g) The extent to which another state may have an interest in
regulating the activity; and
(h) The likelihood of conflict with regulation by another
state.\32\
\32\ Rest. 3d., Third Restatement Foreign Relations Law section
403 (scope of a statutory grant of authority must be construed in
the context of international law and comity including, as
appropriate, the extent to which regulation is consistent with the
traditions of the international system).
To avoid unreasonable interference with the sovereign authority of
foreign regulators, this proposed interpretative statement is supported
and underpinned by principles of international law and comity.
B. Foreign Regulatory Access
In the Commission's view, a foreign regulator's access to data held
in a registered SDR that also is registered, recognized, or otherwise
authorized in a foreign jurisdiction's regulatory regime, where the
data sought to be accessed has been reported pursuant to that
regulatory regime, should be governed by such foreign jurisdiction's
regulatory regime. The Commission concludes that application of the
requirements of CEA section 21(d) in these circumstances is
unreasonable in light of, among other things, the importance of such
data to the foreign jurisdiction's regulatory regime, foreign
regulators' interest in unfettered access to such data, and the
traditions of mutual trust and cooperation among international
regulators.\33\
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\33\ The Commission notes that access to data held by trade
repositories is a concept under discussion and development among
international regulators. At the request of the FSB, CPSS and IOSCO
have established a working group of relevant authorities to produce
a forthcoming report regarding authorities' access to trade
repository data.
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Therefore, the Commission proposes that a foreign regulator's
access to data from a registered SDR that also is registered,
recognized, or otherwise authorized in a foreign jurisdiction's
regulatory regime, where the data to be accessed has been reported
pursuant to that regulatory regime, will be dictated by that foreign
jurisdiction's regulatory regime and not by the CEA or Commission
regulations. Such access is appropriate, in the Commission's view, even
if the applicable data is also reported to the registered SDR pursuant
to the Commission's Data Final Rules.\34\
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\34\ Regarding the Commission's access to SDR data, section
21(b)(1)(A) of the CEA states that the Commission ``shall prescribe
standards that specify the data elements for each swap that shall be
collected and maintained by each registered swap data repository.''
Section 21(c)(1) of the CEA requires registered SDRs to ``accept
data prescribed by the Commission for each swap under subsection
(b).'' Therefore, with respect to Commission access to data held in
registered SDRs, the Commission concludes that the direct electronic
access provisions of CEA section 21(c)(4) apply only to such data
that the SDR is required to accept under section 21(c)(1), which is
further defined by part 45 of the Commission's regulations. In this
respect, the Commission concludes that its direct electronic access
applies only to such data reported pursuant to section 21 and
Commission regulations promulgated thereunder.
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[[Page 26713]]
Additionally, the Commission reiterates that a foreign regulatory
authority, like domestic regulators, can nonetheless receive
confidential data, without the execution of a confidentiality and
indemnification agreement, from the Commission (as opposed to an SDR)
pursuant to section 8(e) of the CEA.\35\ Such data sharing and access
would be governed by the confidentiality provisions of section 8 of the
CEA.
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\35\ As noted above, CEA section 8(e) allows the Commission to
share confidential information in its possession obtained in
connection with the administration of the CEA with ``any department
or agency of the Government of the United States'' or with any
foreign futures authority or a department, central bank or ministry,
or agency of a foreign government or political subdivision thereof,
acting within the scope of its jurisdiction. The Commission
acknowledges the difficulty that registered SDRs may face in
determining what data or reporting falls within the jurisdiction of
a regulatory authority. In this regard, the Commission is
considering a separate release regarding section 2(i) of the CEA.
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C. Request for Comment
The Commission requests comment on all aspects of its proposed
interpretative statement. In particular, the Commission requests
comment on the following issue: How would the timing and implementation
of foreign jurisdictions' regulatory regimes affect the Commission's
proposed interpretative guidance?
By the Commission.
Dated: Issued in Washington, DC, on April 30, 2012.
David A. Stawick,
Secretary of the Commission.
Appendices To Swap Data Repositories: Interpretative Statement
Regarding the Confidentiality and Indemnification Provisions of Section
21(d) of the Commodity Exchange Act Interpretive Statement--Commission
Voting Summary and Statements of Commissioners
Note: The following appendices will not appear in the Code of
Federal Regulations.
Appendix 1--Commission Voting Summary
On this matter, Chairman Gensler and Commissioners Sommers,
Chilton, O'Malia and Wetjen voted in the affirmative; no
Commissioner votes in the negative.
Appendix 2--Statement of Chairman Gary Gensler
I support the proposed interpretative statement regarding the
application of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act) indemnification provisions for swap
data repositories (SDRs). The Commission is working closely with
international regulators on a collaborative approach regarding how
data may be accessed by regulators. The proposed guidance, which
benefited from international input, states the Commission's view
that foreign regulators will not be subject to the indemnification
provisions in the Dodd-Frank Act if the SDR is registered,
recognized or otherwise authorized by foreign law and the data to be
accessed is reported to the SDR pursuant to foreign law. The public
will now have an opportunity to comment on the proposed guidance,
and I look forward to the public's input.
Appendix 3--Statement of Commissioner Jill E. Sommers
I concur in the issuance of this Proposed Interpretative
Statement Regarding the Confidentiality and Indemnification
Provisions of Section 21(d) of the Commodity Exchange Act (Proposed
Interpretive Statement). It provides some additional clarification
with respect to how the Commission intends to interpret the
application of the Section 21(d) indemnification provisions beyond
what the Commission stated when it finalized the swap data
repository (SDR) rules. See Swap Data Repositories: Registration
Standards, Duties and Core Principles, 76 FR 54,538 (Sept. 1, 2011).
However, a legislative fix is the only real solution to providing
appropriate regulators, both foreign and domestic, with timely
access to relevant data. I agree with Commissioner O'Malia that the
Commission should publicly support repeal of the indemnification
provisions, and note that the SEC has already done so.
When finalizing the SDR rules, the Commission stated that a
foreign regulator may have direct access to confidential swap data
reported to and maintained by an SDR registered with the Commission
without executing a Confidentiality and Indemnification Agreement
when the SDR is also registered with the foreign regulator and the
foreign regulator is acting in a regulatory capacity with respect to
the SDR. See id. at 54,554. The Proposed Guidance clarifies that
this should be the case even if the data the foreign regulator seeks
also has been reported pursuant to the CEA and Commission
regulations.
Aside from making this point, the Proposed Interpretive
Statement does not provide any information that cannot be otherwise
gleaned from the SDR final rules, with one notable exception. The
final SDR rules define an ``Appropriate Foreign Regulator'' as one
that has supervisory authority over an SDR that is registered with
the foreign regulator and with the CFTC. The Proposed Interpretive
Statement expands this concept to SDRs that are registered,
recognized, or otherwise authorized in a foreign jurisdiction's
regulatory regime. Thus, registration and recognition are
equivalent. This is a welcome clarification and a step in the right
direction.
I should note that the indemnification provisions of Section
21(d) may have an adverse effect on U.S. regulators too. The
Proposed Interpretive Statement touches on a distinction drawn in
Part 49 between ``Appropriate Domestic Regulators,'' which include a
number of domestic regulatory authorities, and an ``Appropriate
Domestic Regulator with Regulatory Responsibility over a Swap Data
Repository'' (a single entity subcategory of Appropriate Domestic
Regulators, namely, the Securities and Exchange Commission (SEC)).
Only the latter category of domestic regulator (i.e. the SEC) is
exempt from the indemnification provisions of Section 21(d). While
it makes sense that the SEC should be able to receive SDR data
directly from an SDR absent an indemnification agreement, I
encourage comments as to whether other Appropriate Domestic
Regulators should have similar access.
Appendix 4--Statement of Commissioner Scott D. O'Malia
I concur in support of the Commission's proposed interpretative
statement (``Proposed Interpretative Statement'') regarding the
confidentiality and indemnification provisions of Section 21(d) of
the Commodity Exchange Act (``CEA'').
Ultimately, Congress should repeal the confidentiality and
indemnification provisions of Section 21(d) of the CEA and the
Commission should publicly support that repeal. Absent a legislative
fix, however, I believe the Commission is taking the right step to
allay the concerns expressed by many foreign regulatory authorities.
I am somewhat concerned that the Proposed Interpretative
Statement does not address one important issue. Specifically, the
Proposed Interpretative Statement would not provide foreign
regulatory authorities with access to swaps data if those
authorities had not yet finalized their regulations. In order to
better understand the public's view on this issue, I have added a
question seeking comment on how the timing and implementation of
foreign jurisdictions' regulatory regimes should affect the
Commission's final interpretation.
Lastly, I am pleased that this Proposed Interpretative Statement
is based on principles of international harmonization and comity.
The Commission should continue to consult with foreign regulatory
authorities in a manner consistent with international agreements
regarding the registration of swap data repositories and the sharing
of swaps data. In my view, these principles should establish the
foundation of the Commission's forthcoming rulemaking concerning the
extraterritorial application of the Dodd-Frank Act to foreign-based
entities. Several foreign jurisdictions are in the process of
finalizing new rules for the regulation of swaps and it is important
that those rules provide a level and competitive playing field for
U.S. firms as well.
[FR Doc. 2012-10918 Filed 5-4-12; 8:45 am]
BILLING CODE 6351-01-P