Designated Contract Market Regulation - Comment Letter - OneChicago - February 22, 2011
|Final Rule Issue||Effective Date||Compliance Date|
|June 19, 2012||August 20, 2012||October 17, 2012|
Core Principles and Other Requirements for Designated Contract Markets
February 22, 2011
From the comment letter:
"None of the provisions regarding SFP have been amended, renumbered or repealed by Dodd-Frank, yet the CFTC has apparently decided unilaterally to adjust certain important regulations that impact security futures products. We believe that only Congress, and not the CFTC, has that authority."
Regarding Core Principle 9 (CP9), OneChicago argues that security futures products (SFPs) should be treated differently than other future products, because "price discovery does not happen in the security futures price market, price discovery happens in the deep, liquid organized cash market for the underlying equity." Furthermore, they argue that SFP margins and deliveries differ significantly from other futures products.