Derivatives Clearing Organizations Regulation - Comment Letter - Kansas City Board of Trade - 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

KCBT argues that "due to the adequacy of rules and procedures currently in place, we do not see any benefit to certify to the Commission on an annual basis that we are in compliance with the governance fitness standards." In addition, "the requirement of submitting prescriptive, voluminous and detailed information ignores the basic principles of self-regulation and thrusts the Commission into the role of a front line regulator."


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