Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - Futures Industry Association - August 8, 2011
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Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011
From the comment letter:
"The nature and scope of the obligations that would be imposed on Commission registrants and non-registrant members of DCMs and SEFs under the proposed amendment is unclear and, in one case, simply impossible to meet. Moreover, the Commission has substantially underestimated the potential costs that Commission registrants would incur in complying with the recording requirement.
FIA also opposes the proposed amendment to Rule 1.31, which would require Commission registrants to maintain paper records in their original form for a period of at least five years. The Commission has provided no support for such a dramatic reversal of policy. Further, the Commission has failed to provide any meaningful estimate of the potential costs that Commission registrants would incur in complying with the proposed record retention requirement."