Derivatives Clearing Organizations Regulation - Comment Letter - Bloomberg - November 17, 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 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."


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