Reopening and Extension of Comment Periods - CFTC - Comment Letter - BlackRock - June 3, 2011

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Dodd-Frank Act - Reopening and Extension of Comment Periods - CFTC
June 3, 2011

From the comment letter:

“We encourage the Commissions to issue joint final rules to ensure that entities with dual registrations do not find themselves operating under competing regulatory regimes. In addition, where other regulatory agencies are adopting rules on the same subjects that the Commissions are addressing, such as the prudential regulators’ rules on margin, we likewise encourage the Commissions to effect a joint rule making. In addition, we encourage the CFTC and SEC to engage foreign regulators to take a flexible, harmonized approach towards devising regulatory framework for swaps. Swaps in one market are often hedged in or linked to other markets, and it is critical that market participants and swap trading in different jurisdictions operate in a compatible manner so that some rules are not more rigid than others.”


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