Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - Futures Industry Association - August 8, 2011

From MarketsReformWiki
Jump to: navigation, search
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

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."



References

MarketsReformWiki Sponsors

RSM US LLP ADM Investor Services Cinnober Fidessa