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

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

Although CME commends Chairman Gensler for directing attention to the sequencing and timing of rulemaking under Dodd-Frank, CME believes that “some rule proposals should be finalized earlier in the process in order to avoid disruption to the markets and to provide context and clarity to other rulemakings. We also believe that the Chairman’s list should be expanded to include four related rulemakings that are necessary to fully implement the rules on his agenda, in particular, those rulemakings that relate to implementation of the clearing mandate. Logical Sequencing of the rules is critical to meaningful public comment and effective implementation as well as preventing uncertainty in futures and swaps markets. DFA requires many intertwined rulemakings with varying deadlines. Market participants, including CME Group cannot fully understand the implications or costs of a proposed rule when that proposed rule is reliant on another rule that is not yet in its final form. As a result, interested parties are unable to comment on the proposed rules in a meaningful way, because they cannot know the full effect. We recommend that the Commission adopt rules in three stages.”


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