Futures Commission Merchant Regulation - Comment Letter - ISDA - 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:

"ISDA agrees with the Commission’s selection of the Complete Legal Segregation Model as the most appropriate choice of holding model for cleared swaps collateral. ISDA regards this selection as an important first step in arranging appropriate customer protections against FCM failure. ISDA sees porting as one of the most important of these protections and offers below additional mechanisms in support of porting. We also highlight certain bankruptcy issues that may affect more difficult FCM liquidations and hope to elicit Commission interest in helping to resolve these issues, if not within this rulemaking, then over the longer term."



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