Derivatives Clearing Organizations Regulation - Comment Letter - CME Group - February 14, 2011

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Dodd-Frank Timeline, Reporting, Recordkeeping, Public Information and Information Sharing Requirements for DCOs
Proposal Date Final Rule Issue Effective Date
December 13, 2010 October 18, 2011 January 9, 2012

Information Management Requirements for Derivatives Clearing Organization
February 14, 2011

From the comment letter:

"While CME Group is happy to comply with the proposed reporting requirements, we urge the CFTC to work with DCOs to determine the form and manner in which information will be supplied, particularly with regard to information required to be reported on a daily basis relating to positions and margin requirements.

CME Clearing staff and the clearing member typically exchange written correspondence with respect to audit findings and the resolution thereof. In certain instances, this process results in a staff recommendation to the CHRC that sanctions be imposed against the member firm. We do not believe that any stage in this process can be equated to “initiating a rule enforcement action against a clearing member.” A better approach would be to eliminate the requirement that DCOs report the initiation of rule enforcement actions against clearing members and simply require them to report when they impose sanctions against clearing members."


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