Foreign Boards of Trade Regulation - Comment Letter - Natural Gas Exchange - 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

In the comment letter, Natural Gas Exchange (NGX) offers several comments on the proposal, including:

  • Allowing FBOTs with pending no-action relief requests prior to the enactment of the Dodd-Frank Act to be treated the same as those entities who had previously been granted relief would "ease the administrative burden" on the commission.
  • The commission should clarify its intention that swaps contracts may be available for execution on an FBOT through direct market access even if the swap is not cleared.
  • The commission should clarify its definition of a "linked contract," especially as it pertains to "basis contracts," which, although they provide for physical delivery of the commodity, are not cash settled to the price of another market.

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