Cross-Border Activities Regulation - Comment Letter - CME Group - August 21, 2013

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Dodd-Frank Timeline, Cross-Border Application of Swap Entity Provisions, SEC
Final Rule Posted Effective Date Final Rule - Non-U.S. Persons
July 9, 2014 September 8, 2014 February 10, 2016

From the comment letter:

"...in developing a cross-border approach to SBS regulation, the SEC should seek harmonization not only with international regulators, but also with the Commodity Futures Trading Commission (the "CFTC"), which has recently adopted its final cross-border guidance for swaps regulation. With these considerations in mind, CME Group respectfully submits comments as follows:

  1. The location of clearing a SBS should not be a factor in assessing whether a non-U.S. person qualifies as a security-based swap dealer ("SBSD") or major security-based swap participant) ("MSBSP") for purposes of the DFA and the Commission's regulations; and
  2. Any system that requires a clearinghouse to make data reports regarding cleared SBS to a third-party repository is inefficient and costly (and not statutorily mandated as far as regulatory reporting is concerned); any required reporting should allow the clearing agency that clears an SBS to select the SDR to which the cleared SBS is reported.

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