Swap Dealers and Major Swap Participants Regulation - Required Compliance Policies - Comment Letter - Rosenthal Collins Group - January 18, 2011

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Dodd-Frank Timeline, Required Compliance Policies
Final Rule Issue Effective Date Compliance Date, Non-Covered Firms Compliance Date, Covered Firms
April 3, 2012 June 4, 2012 September 30, 2012 March 31, 2013

Required Compliance Policies; Designation of Chief Compliance Officer
January 18, 2011

From the comment letter:

  • "To require the CCO of an FCM to also be a principal—and possibly liable outside his/her area(s) of competence or control adds no incentive for qualified individuals to become or stay as CCOs of FCMs."
  • "The Commission rule on CCOs of FCMs, in our view, should be in the nature of a “broad brush” and not get involved in detail. The Proposal, in our view, would place an unduly heavy burden on the CCO of an FCM. Words like “full responsibility” to “develop and enforce” rules and procedures at an FCM could have a chilling effect on anyone qualified from taking on the CCO role."
  • "We believe that by making the CCO of an FCM “liable” for infractions by the firm and, by the proposed CCO’s annual detailed certification, giving potential “disgruntled” customers a “roadmap” for frivolous lawsuits, the Proposal does a disservice not only to FCMS, but also to the public interest."



References