Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - CME Group - August 8, 2011

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Dodd-Frank Timeline, Amendments to Adapt Certain CFTC Regulations to the Dodd-Frank Act
Final Rule Issue, Bunched Orders Final Rule Issue, Adaptations Final Rule Issue, Recording of Transactions
April 9, 2012 October 16, 2012 January 2, 2013

Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

In their comment letter, the CME Group explains that:

  • The proposed oral recordkeeping requirements would be unduly burdensome to covered intermediaries and have not been shown to be necessary
  • If the Commission chooses to proceed, it should clarify several aspects of the proposed oral recordkeeping requirements
  • The proposed amendments to rule 1.31(a) also need clarification
  • The Commission's proposals lack an adequate cost-benefit analysis
  • The proposed amendments to “Open Contracts” do not accurately reflect market realities


References

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