Swap Entities Regulation - Comment Letter - Eris Exchange - September 30, 2011

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Dodd-Frank Timeline, Customer Clearing Documentation and Timing of Acceptance for Clearing
Final Rule Issue Effective Date Compliance Date, FCMs, DCMs, DCOs Compliance Date, SEFs
April 9, 2012 October 1, 2012 October 1, 2012 TBA

Customer Clearing Documentation and Timing of Acceptance for Clearing
September 30, 2011

From the comment letter:

Eris Exchange supports the Proposed Rules and believes they are necessary to promote the overall goals of the Dodd-Frank Act of reducing systemic risk and bringing greater transparency to the over-the-counter markets. Specifically, Eris Exchange believes that:

  • the well-established futures model for execution and clearing implements the goals of the Proposed Rules and therefore provides a baseline for the documentation in the cleared swaps market
  • technology exists today to implement the execution and clearing of derivatives
  • there is no need for an execution agreement that sets up a direct legal relationship between the buyer and the seller
  • the Futures Model ensures open access to any person with an account at a Futures Commission Merchant, including smaller buy side firms


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