Reopening and Extension of Comment Periods - CFTC - Comment Letter - Consortium of Trade Associations - May 26, 2011

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Dodd-Frank Act - Reopening and Extension of Comment Periods - CFTC
May 26, 2011

This comment letter expresses the opinions of the following organizations:

  • Futures Industry Association,
  • The Financial Services Roundtable,
  • Institute of International Bankers,
  • Insured Retirement Institute,
  • International Swaps and Derivatives Association,
  • Securities Industry and Financial Markets Association, and
  • U.S. Chamber of Commerce.

From the comment letter:

"We recommend that the Commission re-propose the CFTC Proposed Rules in a manner that reflects, as appropriate, the incorporation of prior public comments. We further suggest that the Commission then allow for a final comment period for all the rules in their entirety that runs from the date of the last proposed rule. Finally, where appropriate, we ask that the Commission wait to be informed by additional data before proceeding with market data-driven rules, such as, for example, real-time reporting. By providing market participants with the opportunity to comment more meaningfully on the new regulatory structure, the Commission will be better able to draft effective final rules and ensure that it has used a process that provides for the least possibility of unintended consequences, adverse market impact and anti-competitive impact while still achieving the objectives of the Dodd-Frank Act."


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