Derivatives Clearing Organizations Regulation - Comment Letter - Morgan Stanley - November 17, 2010

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DCO, DCM, SEF Governance Standards
Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges With Respect to Security-Based Swaps Under Regulation MC
November 17, 2010

From the comment letter:

Morgan Stanley expresses their concern that "without certain revisions, the Proposals could inadvertently reduce market competitiveness and impair the ability of these entities appropriately to manage their risks. In particular, the proposed 40 percent aggregate equity ownership limitations on clearinghouses should be eliminated in order to foster a vibrant and competitive market... In addition, Morgan Stanley recommends that the Commissions eliminate the requirements that DCOs' and security-based swap clearing agencies' (SB SCAs') risk management committees include public or independent directors, and that the independent director requirement for boards of directors as a whole should not be increased above 35 percent."


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