Designated Contract Market Regulation - Comment Letter - Intercontinental Exchange - February 22, 2011

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Dodd-Frank Timeline, Core Principles and Other Requirements for Designated Contract Markets
Final Rule Issue Effective Date Compliance Date
June 19, 2012 August 20, 2012 October 17, 2012

Core Principles and Other Requirements for Designated Contract Markets
February 22, 2011

In the letter, Intercontinental Exchange, Inc. offers specific recommendations to the CFTC regarding the DCMs:

  • Adopt a less restrictive approach to implementing Core Principle 9’s centralized trading requirements;
  • Have different centralized trading requirements for liquid front months versus less liquid distant months;
  • Clarify that Requests for Cross meet the centralized trading requirement;
  • Adopt a less prescriptive approach to the pricing of block trades between affiliated parties and the timing of reporting block trades; Not adopt requirements on the pricing and time of reporting for exchanges of derivatives for related positions;
  • Allow the execution methods for swaps listed on a DCM to be similar to those available on a swaps execution facility (“SEF”);
  • Not require the real-time monitoring of intraday position limit rules by DCMs until the technology is readily available;
  • Allow DCMs to rely on clearing member guarantees when complying with financial integrity standards; and
  • Allow DCMs to distinguish between traders with intermediated access and direct access when adopting rules to comply with Core Principle 2.

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