​The Edison Electric Institute (“EEI”) and the National Rural Electric Cooperative Association (“NRECA”) (hereafter “Joint Associations”) respectfully submit these comments in response to the Notice of Proposed Rulemaking on Capital Requirements of Swap Dealers (“SDs”) and Major Swap Participants (“MSPs”) (the “Proposed Regulatory Capital Rules”) issued by the Commodity Futures Trading Commission (“CFTC” or “Commission”).¹  FULL FILING