Foreign Boards of Trade Regulation - Comment Letter - NASDAQ OMX - 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:

"Our main concern related to the proposed rules is that they will involve a quite extensive process in order to obtain and maintain registration. Even the limited application process for FBOTs with existing no-action relief letters will involve a considerable amount of work. In our view, the registration requirements seem more detailed and extensive than strictly necessary in order to fulfill the objectives set out in the Dodd-Frank Act...Further, in order to provide more flexibility, it is our opinion that the registration requirements should refer to “recognized international standards”..."


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