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

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

From the comment letter:

“MarkitSERV provides these comments to the Commission primarily in response to a rule proposed by the SEC. In its rule on Clearing Agency Standards for Operation and Governance, the SEC has proposed to require certain providers of post-trade services, including certain providers of confirmation services, to register with the SEC as Clearing Agencies. The CFTC, on the other hand, has made no similar proposal. We believe that regulating these entities in the SEC-regulated market but not in the CFTC-regulated market would have detrimental market effects, would create unnecessarily inconsistent regulations and would result in regulatory gaps in the regulations mandated by the DFA. An important market function, such as providing confirmation services, should be subject to a robust, uniform and pervasive regulatory regime in the U.S. to ensure the safety, resiliency, and efficiency of the U.S. derivatives markets. We therefore believe that the Commission should also regulate facilities that perform the confirmation and processing of swaps. The Commission can carry out such regulation either by establishing a new kind of regulated and registered IVS entity or by recognizing and regulating IVSs as a sub-category of swap execution facilities, derivatives clearing organizations, or swap data repositories.”



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