Derivatives Clearing Organizations Regulation - Comment Letter - Commercial Energy Working Group - September 20, 2012

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Timeline-Inter-Affiliate Swaps
Proposal Date Final Rule Issue Effective Date
August 21, 2012 April 11, 2013 June 18, 2013

Clearing Exemption for Swaps between Certain Affiliated Entities
September 20, 2012

From the comment letter:

"Many commercial enterprises use a corporate structure with multiple entities and transactions, including swaps, between such entities for a number of business purposes such as to: (i) efficiently allocate risks and responsibilities among affiliated entities; (ii) optimize tax consequences; and (iii) comply with customs, licensing and other regulatory requirements for doing business in certain jurisdictions. In this context, inter-affiliate swaps serve legitimate business purposes, such as risk management, accounting, and treasury management.2 Requiring the conditions in the Proposed Rule to be satisfied to avoid central clearing in certain circumstances or to require central clearing of inter-affiliate swaps in any circumstance would render what is often an internal management matter too costly for its intended purpose."

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