In December 2016, the Commodity Futures Trading Commission (“CFTC”) released its re-proposed capital rules for swap dealers (“SDs”) and major swap participants (“MSPs”).1 Additionally, the Securities and Exchange Commission (“SEC”) proposed its capital rules in 20122 for security-based SDs and MSPs. The CFTC’s re-proposal attempts to accomplish several things, including harmonization with the proposed SEC capital rules. It further provides optionality for financial and non-financial SDs regarding computing capital under a standardized versus models-based approaches.3 It is important for each financial SD to assess the implications of the proposed rulemaking to its swap dealing operating model. Questions to consider include: (1) Why should SDs consider a models-based capital approach versus non-model? (2) How does entity type (e.g., bank, broker-dealer) impact capital methodology?