November 12, 2010
On November 12, 2010, spoke at a symposium on financial regulatory reform hosted by George Washington University Center for Law, Economics, and Finance. His remarks centered on:
- The need to increase mortgage midifications;
- The "long road ahead" of Dodd-Frank Act regulatory reform;
- Basel III, leverage ratios, and its minimum common equity ratio, which will be set at 4.5% of risk-weighted assets, with an additional requirement for a 2.5% “conservation buffer.”
Testimony by John Damgard, FIA President, on Dodd-Frank Act
February 15, 2011
On February 15, 2011, John Damgard, president of the Futures Industry Association (FIA), testified before the House Committee on Agriculture Subcommittee on General Farm Commodities and Risk Management. His written and oral statements can be found below.
Summary of the Statement
- What has worked regarding addressing risks in the futures market will be insufficient to deal with the bilateral swaps market.
- The one-year implementation deadline is insufficient for thorough analysis and comment on proposed rule changes.
- Proposed monitoring, reporting, and recordkeeping requirements represent significant cost burdens, which will "force many FCMs to withdraw from the business and the barriers to entry will be raised."
- The commission's proposed rules on, among other things, conflicts of interest, governance, and chief compliance officer duties, go beyond the intent of Dodd-Frank.
- Essential decisions on the most critical issues, such as "swaps definitions," margin requirements, and international swaps jurisdiction, have not been adequately addressed.
- Delay the adoption of final rules until "all affected participants have a reasonable opportunity to analyze fully and understand the scope of the regulatory regime."
- Delegate swaps responsibilities to the National Futures Association (NFA).