Covered Swap Entities Regulation - Comment Letter - BNY Mellon/Northern Trust/State Street - July 11, 2011

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Dodd-Frank Timeline, Margin and Capital Requirements for Covered Swap Entities
Re-proposed Rule Issue Final Rule Issue Effective Date
September 24, 2014 October 22, 2015 April 1, 2016

Margin and Capital Requirements for Covered Swap Entities
July 11, 2011

From the comment letter:
"While the Custodian Banks believe the use of independent custody for swaps margin provides high levels of protection for each counterparty to a swap, for the reasons set forth herein, we are concerned that including the insolvency regime-related requirement in a final rule would not mitigate risks faced by Swap Entities that enter into Uncleared Swaps and would have undesirable consequences. Accordingly, we respectfully request that the insolvency regime requirement be excluded from the final rulemaking."


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