Derivatives Clearing Organizations Regulation - Comment Letter - IntercontinentalExchange - March 7, 2011
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| 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
March 7, 2011
From the comment letter:
ICE reminds the Commission that DCMs and DCOs have operated well under the existing conflict of interest and governance Core Principles and Commission regulations for over a decade.
Accordingly, the Commission should:
- defer implementing any public disclosure requirement regarding board decisions to supersede Risk Management Committee (“RMC”) decisions, until the Commission has studied the interaction between DCO governing boards and their RMCs
- allow DCMs to distinguish between traders with intermediated access and direct
- delete the requirement that a DCO obtain a consent to jurisdiction from persons with direct access to a DCO’s settlement and clearing activities
- delete the prohibition that legal staff of a swaps execution facility (“SEF”), DCM or DCO may not be designated to address conflict of interest issues.
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