Swap Data Regulation - Comment Letter - CME Group - February 7, 2011

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Dodd-Frank Timeline, Real Time Public Reporting of Swap Transaction and Pricing Data
Final Rule Issue Effective Date Compliance Date
December 20, 2011 March 9, 2012 December 31, 2012

Real Time Public Reporting of Swap Transaction and Pricing Data
Swap Data Recordkeeping and Reporting Requirements
February 7, 2011

From the comment letter:

"The Commission should clarify in its final rules that each initial regulatory report for a cleared swap must be directly reported to the applicable DCO or SDR chosen by such DCO (“DCO-SDR”). This approach is the lowest cost and least burdensome method for implementing the regulatory reporting requirements."

"DCOs will necessarily have already established connections with relevant execution venues and other market participants for cleared trades. These existing connections can be used for reporting purposes as well. Requiring entirely redundant reporting channels to non-DCO SDRs for cleared trades is at best unnecessary and costly and at worst could create unnecessary ambiguity about the true state of a trade or position."



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