Customer Protection Regulation - Comment Letter - Commodity Customer Coalition - February 15, 2013

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Timeline, Enhanced Customer Protections, CFTC
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:

"While we applaud the efforts and intent behind the Proposed Rules, many of them would increase the risk of FCM insolvency, increase the magnitude of FCM insolvency by vastly increasing concentration risk and require commodity customers to greatly increase the capital they tender to their FCM to margin their positions. The malfeasance of some FCMs should not be corrected by asking commodity customers to provide more money to every FCM with which they do business.

Therefore the CCC respectfully requests that the CFTC refrain from implementing the Proposed Rules so that it can work more closely with industry constituents on their revision, as well as other means to achieve the goals of the Proposed Rules."

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