SEC Final Rule on Business Conduct Standards for Swap Dealers (June 26, 2018)

Financial Services

The Church Alliance submitted a comment to the Securities and Exchange Commission (“SEC”) regarding possible revisions of regulations promulgated by the SEC on business conduct standards for security-based swap dealers and major security-based swap participants (“SBC Entities”). The Church Alliance noted that the SEC rule was inconsistent with an earlier rule promulgated by the Commodity Futures Trading Commission (“CFTC”), in a manner that could be detrimental to church plans. In particular, the Church Alliance noted that the SEC rule, requiring treatment of church plans as “special entities” unless they opt-out, places an additional burden on church plans. The Church Alliance asked the SEC to consider the costs associated with inconsistent rules, and consider revising its rule to harmonize with that of the CFTC.