“AFR is disappointed at the continuing extension of exemptions from swaps reporting for foreign dealers active in the U.S. markets. Some of the transactions to which this relief applies, such as transactions with supposedly non-guaranteed affiliates of U.S. banks, could be highly relevant to derivatives risks within the U.S. economy. (As we have previously argued, major foreign affiliates of U.S. banks qualify for classification as “non-guaranteed” under current CFTC rules.) If foreign jurisdictions are unable to complete swaps reporting rules that satisfy U.S. standards, the U.S. must take action to force the clear reporting of derivatives risks that are connected to the U.S. financial system.”