Futures Commission Merchant Regulation - Comment Letter - FIA/ISDA - December 2, 2010

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Dodd-Frank Timeline, Investment of Customer Funds
Final Rule Issue Effective Date Compliance Deadline
December 19, 2011 February 17, 2012 June 18, 2012

Investment of Customer Funds and Credit Ratings
December 2, 2010

FIA and ISDA are "concerned that several of the proposed revisions are inconsistent with the Commission’s goals, may increase systemic risk or may have significant unintended consequences," particularly with the proposals to:

  • prohibit entirely investments in the securities of government sponsored enterprises (“GSEs”) and corporate obligations (unless such securities are guaranteed as to principal and interest by the United States) and all foreign sovereign debt,
  • limit the investment in money market mutual funds to 10 percent of investible assets held in segregation and
  • prohibit repurchase and reverse repurchase transactions with affiliated banks and registered broker-dealers (as well as so-called “in-house” transactions).


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