On June 29, 2011, the U.S. Securities and Exchange Commission (the “SEC”) issued proposed rules to implement provisions of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 related to certain business conduct standards for security-based swap dealers and major security-based swap participants. The SEC’s proposal implements statutory provisions substantially identical to those addressed by the U.S. Commodity Futures Trading Commission (the “CFTC”) in its December 2010 proposal for external business conduct standards. Comments on the SEC’s proposal are due by August 29, 2011. The attached memorandum reviews the proposed business conduct standards and compares the SEC’s and CFTC’s proposals.
