IACPM responds to the Securities and Exchange Commission Consultation on the Prohibition Against Fraud, Manipulation or Deception in Connection with Security – Based Swaps; Prohibition Against Undue Influence over Chief Compliance Officers; Position Reporting of Large Security – Based Swap Positions.  IACPM’s members are concerned that these two rules may impact credit portfolio management hedging activities.

 

Click here to access the comment letter
Click here to access the SEC Consultation