Customer Protection Regulation - Comment Letter - Newedge - 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:

"The CFTC itself observes that adoption of its proposed rules will be costly. For example, the CFTC notes that the proposals are likely to cost individual FCMs between $193,000 and $1.85 million initially and $287,000 and $2.3 million annually to implement them. Newedge believes these numbers only partially reflect the expense to implement the CFTC's proposed rules, and ignore other material costssuch as the increased capital and liquidity necessary to enact many of the proposals...As a result, Newedge agrees with the FIA and urges the CFTC to refine its cost-benefit analysis and carefully consider the impact before it adopts any final rules."

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