Derivatives Clearing Organizations Regulation - Comment Letter - IntercontinentalExchange - March 7, 2011

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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
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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