Futures Commission Merchant Regulation - Comment Letter - Futures Industry Association - August 8, 2011

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Dodd-Frank Timeline, Protection of Cleared Swaps Customer Contracts and Collateral, Commodity Broker Bankruptcy Provisions
Final Rule Issue Effective Date Compliance Date
February 7, 2012 April 9, 2012 November 13, 2012

Protection of Cleared Swaps Customer Contracts and Collateral; Conforming Amendments to the Commodity Broker Bankruptcy Provisions
August 8, 2011

From the comment letter:

"FIA has carefully reviewed both the several alternatives set out on the Federal Register release and the proposed rules. We have concluded that both the complete legal segregation model and the futures model meet the underlying purposes of section 4d(f) identified above...however, we do not believe that (i) physical segregation, (ii) legal segregation with recourse, or (iii) the optional model are practical solutions for the protection of cleared swaps collateral."

In the letter, FIA poses several questions regarding the treatment of variation margin, limitations on use of customer collateral, currency-by-currency segregation, location of securities depositories, time allotted to meet margin calls, FCM disclosures, and the treatment of funds in omnibus accounts.


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