Customer Protection Regulation - Comment Letter - LCH.Clearnet - January 25, 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
January 25, 2013

In the comment letter, LCH.Clearnet recommends the consideration of alternative approaches for routine access to account balances. LCH suggests following the lead of the NFA in utilizing third party audit confirmation.

Also, LCH is concerned that certain residual interest rules will have unintended consequences, such as giving FCMs an incentive to hold less of a capital buffer at the DCO in favor of holding excess capital at the FCM level.

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