Futures Commission Merchant Regulation - Comment Letter - Farm Credit Administration - December 3, 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 3, 2010

From the comment letter:

"The proposed rule may have potential unintended consequences for GSEs that should be explored and evaluated...By excluding all GSE debt from the securities available for use in customer-segregated accounts, the CFTC's proposed rule has the potential to alter the market for GSE debt. To our knowledge, no GSE debt has ever resulted in a loss of principal or interest to any investor."


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