Customer Protection Regulation - Comment Letter - CME Group - February 15, 2013
|Proposal Date||Comment Deadline||Final Rule Approved||Effective Date|
|November 14, 2012||February 15, 2012||October 30, 2013||January 13, 2014|
Enhancing Protections Afforded Customers and Customer Funds Held by FCMs and DCOs
February 15, 2013
From the comment letter:
"In this comment letter, CME also offers comment on proposed changes to CFTC Regulation 1.52. CME supports the Commission’s goal of evaluating whether any changes should be made to the risk-based examinations currently performed on FCMs. Indeed, CME, in conjunction with the Joint Audit Committee (“JAC”) and the CFTC, regularly reviews its procedures and makes changes to those procedures so that they are continually evolving and improving. We are concerned, however, that instead of proposing changes narrowly designed to address perceived weaknesses in the current regulations, the Commission proposes to fundamentally overhaul the nature of the reviews performed by self-regulatory organizations (“SROs”) and designated self-regulatory organizations (“DSROs”) and, in so doing, threaten the viability of the current regulatory structure. This is a drastic measure that is not supported by an adequate cost benefit analysis. Our specific concerns regarding the proposed changes to Regulation 1.52 are detailed below in Section V."