Covered Swap Entities Regulation - Comment Letter - Deutsche Bank - 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:

"We do not believe, however, that the broad-brush distinctions made in the Proposed Rules between types of derivatives counterparties are in fact useful in distinguishing among the risks posed by each type. We are concerned that the Prudential Regulators’ overly prescriptive approach will lead to unnecessary costs, inefficiencies and illiquidity without a corresponding benefit in reduced risks. Overly burdensome requirements on margin and margin segregation will generate a substantial cost to the economy due to a reduction in available liquidity and the supply of capital."


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