Futures Commission Merchant Regulation - Comment Letter - IntercontinentalExchange - January 18, 2011

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Protection of Cleared Swaps Customers Before and After Commodity Broker Bankruptcies
January 18, 2011

“ICE submits that the significant and various costs that would be associated with the potential non-Baseline models described in the Commission’s Advanced Notice, (including implementation, administrative, regulatory and compliance, increases in initial margin and systemic costs) would, at each level of the marketplace (customer, FCM, and DCO), far outweigh any benefit. In addition, ICE submits that the Commission’s recently proposed Large Trader reporting and stress testing regulations should serve to mitigate “fellow-customer risk.” Accordingly, ICE suggests that it would be more prudent and practical for the Commission to allow the traditional omnibus (mutualized) clearing model to be applied to customer-related swaps transactions.”


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