Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - Minneapolis Grain Exchange - August 8, 2011

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Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

MGEX explains that there are several pitfalls in adopting 1.35 as proposed. "First, the language is overbroad and vague” and “the scope of the communication which leads to an executed trade needs additional clarification." In addition, "the proposed rulemaking is duplicative, costly and potentially impractical. It is duplicative in that each set of communication – be it oral or written – needs to be preserved and cataloged, even if the substance of the written and oral versions are identical."

"Finally, MGEX believes that there are members who may not trade enough to justify the extreme costs related to the proposed data collection. As a result, these members may effectively be pushed off exchanges based on a cost/benefit analysis. MGEX suggests having a threshold before requiring these heavy burdens apply to these low volume members."


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