Derivatives Clearing Organizations Regulation - Comment Letter - VMAC - February 25, 2011

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Risk Management Requirements for Derivatives Clearing Organizations
February 25, 2011

VMAC suggests that the CFTC revise and add language to the proposed Regulations regarding trade origin dependent liquidation times and initial margin confidence levels. They argue that "Derivative Clearing Organizations should be broadly responsible for setting their own initial margin levels" and that the "CFTC's rules governing risk management requirements should not be so prescriptive as to dictate the confidence level and liquidation time that DCOs use in calculating initial margin."

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