Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - CME Group - August 8, 2011

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Dodd-Frank Timeline, Amendments to Adapt Certain CFTC Regulations to the Dodd-Frank Act
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April 9, 2012 October 16, 2012 January 2, 2013

Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

In their comment letter, the CME Group explains that:

  • The proposed oral recordkeeping requirements would be unduly burdensome to covered intermediaries and have not been shown to be necessary
  • If the Commission chooses to proceed, it should clarify several aspects of the proposed oral recordkeeping requirements
  • The proposed amendments to rule 1.31(a) also need clarification
  • The Commission's proposals lack an adequate cost-benefit analysis
  • The proposed amendments to “Open Contracts” do not accurately reflect market realities


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