Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - IntercontinentalExchange - August 4, 2011

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Dodd-Frank Timeline, Amendments to Adapt Certain CFTC Regulations to the Dodd-Frank Act
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April 9, 2012 October 16, 2012 January 2, 2013

Adaptation of CFTC Regulations to Incorporate Swaps
August 4, 2011

In their comment letter, ICE argues that:

  • The Commission’s proposal to require all participants on a SEF or DCM to record all pre-execution trade information is unnecessary and duplicative
  • The requirement will serve as a large surtax on exchange transactions and will cause end users to take transactions away from Swap Execution Facilities or Designated Contract Markets, defeating the Dodd/Frank Wall Street Financial Reform and Consumer Protection Act’s (“Dodd/Frank”) transparency objectives


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