Swap Dealers and Major Swap Participants Regulation - Comment Letter - Better Markets - September 18, 2011

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Dodd-Frank Timeline, Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants, CFTC
Original Proposal Re-proposal Approved Final Rule Approved
May 12, 2011 September 17, 2014 December 16, 2015

Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
September 18, 2011

Key considerations from the comment letter:

  • "Congress' ultimate objective in the Dodd-Frank Act was to prevent another crisis and the massive costs it would inflict;
  • Prudent margining of uncleared swaps is an integral component of the reforms that Congress decided were necessary to achieve this objective; and
  • The costs of compliance and reduced profit margins that industry may have to absorb by virtue of these margin requirements pale in comparison with the benefits of preventing another crisis - a benefit that can be valued at over $12.8 trillion."

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