Designated Contract Market Regulation - Comment Letter - OneChicago - February 22, 2011

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Dodd-Frank Timeline, Core Principles and Other Requirements for Designated Contract Markets
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"None of the provisions regarding SFP have been amended, renumbered or repealed by Dodd-Frank, yet the CFTC has apparently decided unilaterally to adjust certain important regulations that impact security futures products.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.

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