Staff of the Commodity Futures Trading Commission issued a comprehensive report regarding the so-called “de minimis exception” – namely the maximum quantity of swap dealing a firm may engage in prior to being required to register as a swap dealer. Currently the threshold is US $3 billion aggregate gross notional amount measured over the prior 12-month period. However, an interim threshold of US $8 billion is in effect until December 31, 2017. The report presents an estimation of current swap activity and endeavors to calculate how many additional swap dealers might be required to be registered at different thresholds. However, because of limitations in data quality, staff made assumptions regarding current swap activity and the impact of different thresholds on the number of swap dealer registrants. Staff seeks input on its assumptions; different methodologies to assess how “quantity” might be calculated to assess registration requirements; and whether cleared swaps should be included in the calculation of entities’ gross notional amount of swap dealing, among other topics. Comments are due by January 19, 2016.