Swap Data Regulation - Comment Letter - CME Group - May 14, 2012

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Dodd-Frank Timeline, Block Trade Minimum Size, Protection of Identities, CFTC
Proposal Date Final Rule Issue Effective Date
February 23, 2012 May 31, 2013 July 20, 2013

Procedures To Establish Appropriate Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades
May 14, 2012

CME Group opposes the Commission’s “one size fits all” approach in “determining the swap block levels in the post-initial period because it neither advances the goals of Dodd-Frank nor takes into consideration the individual needs of each particular market.” In addition, they argue that “the 67% rule serves an arbitrary purpose and has no relationship to the explicit goals of Dodd-Frank with respect to block trading of swaps.” They also “believe that if the proposal is made applicable to trading on SEFs and DCMs, it lacks adequate regulatory context given the lack of definition surrounding various aspects of the implementation of Dodd-Frank.”


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