Swap Dealers and Major Swap Participants Regulation - Comment Letter - Principal Traders Group - July 11, 2011

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Dodd-Frank Timeline, Capital Requirements for Swap Dealers and Major Swap Participants
Proposal Date Comment Deadline Final Rule Issue
May 12, 2011 July 11, 2011 TBA

Capital Requirements for Swap Dealers and Major Swap Participants
July 11, 2011

This comment letter was submitted by 27 firms which are all members of the FIA Principal Traders Group.

Summary of key points from the comment letter:

  • There is no policy reason to apply minimum regulatory capital to participants that do not have customers and trade only cleared swaps.
  • Costs from imposing a minimum regulatory capital requirement on entities that do not have customers and that trade only cleared swaps contracts are not balanced by any corresponding regulatory benefit.
  • Financial condition information for swap dealers that do not have customers should remain confidential.


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