Foreign Boards of Trade Regulation - Comment Letter - CME Group - January 18, 2011

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Dodd-Frank Timeline, Registration of Foreign Boards of Trade
Final Rule Issue Effective Date Compliance Date
December 23, 2011 February 21, 2012 August 20, 2012

Registration of Foreign Boards of Trade
January 18, 2011

From the comment letter:

"In our view, reducing or limiting barriers to entry in the global futures and options industry has strongly contributed to business growth and increased competition. This is due, at least in part, to the fact that U.S. market participants can directly and electronically trade foreign futures and options contracts from the U.S...CME believes that the commission's analysis should be more narrowly tailored to determining whether an FBOT is subject to "comparable" regulatory regime by its home country regulator. In contrast to that approach, we have a significant concern that the proposed rules are too prescriptive and would impose significant burdens without corresponding benefit."

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