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

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

In their comment letter, Bloomberg explains “that the Dodd-Frank mandatory clearing and reporting requirements will significantly mitigate systemic risk, promote standardization and enhance transparency. Of an equal but different importance is the creation of the newly regulated SEF marketplace. While all three of foregoing areas are critical under the new Dodd-Frank regulatory regime, we believe that swap clearing and reporting activities benefit from legal certainty and specificity provided by detailed prescriptive rules. SEF trading models, however, will benefit from flexible rules that will help ensure that the markets continue to operate efficiently and effectively…We also believe it is important for the Commission to extend current exemptions from the Commodity Exchange Act for OTC derivatives transactions until such time the Commission adopts rules providing for the comprehensive regulation of the swap market.”


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