Futures Commission Merchant Regulation - Comment Letter - JP Morgan - 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

According to the comment letter, JP Morgan is unable to support certain aspects of the proposal, namely those which:

  • prohibit entirely investments in securities of government sponsored enterprises ("GSEs") (unless such securities are guaranteed as to principal and interest by the United States) and all foreign 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.


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