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

From Markets Reform Wiki
Jump to navigation Jump to search
Dodd-Frank Timeline, DCO,DCM, SEF Governance Standards, Additional Requirements
Proposal Date Comment Deadline Final Rule Issue
January 6, 2011 June 3, 2011 TBA
Dodd-Frank Timeline, Ownership Limitations and Governance Requirements for SBS Entities, SEC
Proposal Date Comment Deadline Reopened Comment Period Deadline
October 26, 2010 April 29, 2011 July 22, 2013

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."

References[edit]

<references /> Category;Conflicts of Interest

MarketsReformWiki Sponsors

RSM US LLP ADM Investor Services Cinnober Fidessa