Reopening and Extension of Comment Periods - CFTC - Comment Letter - Minneapolis Grain Exchange - June 3, 2011

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

MGEX believes that those “proposed rulemakings necessary for implementation and required by the Dodd-Frank Act should be the primary focus of the Commission – that being the transfer of eligible over-the-counter (“OTC”) activity onto exchanges and clearing houses. In general, until those regulations are adequately addressed, it appears that many of the remaining proposed rulemakings will be neither implementable nor enforceable.”

Furthermore, “MGEX maintains that, as the final rules are adopted, the Commission could also adopt a schedule for implementation within each phase. MGEX will primarily be impacted by Phase II of Commissioner O’Malia’s proposed schedule. If all of Phase II is enacted and to be implemented simultaneously, there will be a huge burden placed on the Exchange. Therefore, the Exchange respectfully requests that there be a thoroughly thought-out, staggered, and reasonable adoption and implementation schedule even within each phase.”


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