Reopening and Extension of Comment Periods - CFTC - Comment Letter - Citadel - June 3, 2011

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Dodd-Frank Act - Reopening and Extension of Comment Periods - CFTC
June 3, 2011

In their comment letter, Citadel gives their support for the implementation timeline proposed in the Managed Fund Association’s March 24, 2011 comment letter and offers an alternative phased-in approach as well. Citadel “recommends that the Commissions embody the central clearing implementation timelines In a formal rule and, as a first priority, adopt those rules that directly pertain to central clearing in order to launch the sequence.” In addition, Citadel recommends “an initial Mandatory Clearing Date that is 120 days after the Mandatory Access Date for all dealer-to-dealer transactions as well as for transactions between dealers and the largest and most active buy-side participants.”


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