The Securities and Exchange Commission has proposed business conduct rules for security-based swap dealers and major security-based participants that AFR and CFA have said will not be effective in ending abusive practices and do not do enough to bring transparency to this market. Of particular concern are serious shortcomings in the provisions designed to provide enhanced protections for special entities, such as municipalities and pension funds, shortcomings that all but guarantee the rules will not deliver the intended enhanced protections. In a comment letter filed with the SEC yesterday, AFR and CFA urged the agency to comprehensively revise the rules to address weaknesses in virtually every provision of the rules and make them at least as strong as those proposed earlier this year by the CFTC.