Derivatives Clearing Organizations Regulation - Comment Letter - Bloomberg - November 17, 2010
|Proposal Date||Comment Deadline||Final Rule Proposal|
|October 18, 2010||June 3, 2011||First Qtr. 2012|
|Proposal Date||Comment Deadline||Final Rule Issue|
|January 6, 2011||June 3, 2011||TBA|
DCO, DCM, SEF Governance Standards
November 17, 2010
Bloomberg acknowledges that the CFTC has appropriately identified key variables in "identifying conflicts of interest and generally proposes appropriate measures to improve the governance of SEFs." However, they suggest that "the rule proposals should include a degree of flexibility and discretion in imposing governance requirements on SEFs depending on their ownership structure and other relevant facts and circumstances so that any conflicts of interest requirements are applied meaningfully and appropriately."