Derivatives Clearing Organizations Regulation - Comment Letter - CME Group - February 7, 2011

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Dodd-Frank Timeline, DCO Definitions, Procedures and Core Principles, CFTC
Final Rule Issue Effective Date Compliance Date
October 18, 2011 January 9, 2012 May 7, 2012

Derivative Clearing Organization Definitions, Procedures and Core Principles
February 7, 2011

CME Group believes "the CFTC should not add further restrictions to the Chief Compliance Officer (CCO) role but should retain an approach that gives DCOs flexibility to determine whether their CCOs may perform certain tasks that are not strictly compliance-related." They provide suggestions regarding the proposed CCO responsibilities of ensuring compliance, enforcing compliance policies and procedures, and resolving conflicts of interest. CME Group comments on the annual compliance report regarding certification requirement and confidentiality as well as insulating CCOs from undue pressure or coercion and the implementation period.



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