Derivatives Clearing Organizations Regulation - Comment Letter - BlackRock - November 15, 2010

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Dodd-Frank Timeline, DCO,DCM,SEF Conflicts of Interest Mitigation
Proposal Date Comment Deadline Final Rule Proposal
October 18, 2010 June 3, 2011 First Qtr. 2012
Dodd-Frank Timeline, DCO,DCM, SEF Governance Standards, Additional Requirements
Proposal Date Comment Deadline Final Rule Issue
January 6, 2011 June 3, 2011 TBA

DCO, DCM, SEF Governance Standards
November 15, 2010

In regard to the role that Public Directors play, BlackRock believes that "the Commission should ensure that DCOs cannot deny customers and Public Directors a meaningful voice by delegating its functions to subcommittees." They also argue that "buy-side participants (investors and managers) should be guaranteed a meaningful voice in all activities of the Risk Management Committee and urge the Commission to adopt a mechanism to guarantee buy-side participants real input on governance committees, including DCO Risk Management Committees. The Commission should make certain that clearing members cannot change DCO policies and procedures without support from either customers or Public Directors." To ensure this, they propose two options:

  • The Commission could provide for additional customer representation on the Risk Management Committee to guarantee that customers and Public Directors constitute a majority of the Risk Management Committee.
  • The Commission could require the Committee to act by a super-majority vote of no less than 60%.


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