Swap Dealers and Major Swap Participants Regulation - Comment Letter - CME Group - February 22, 2011

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Dodd-Frank Timeline, Business Conduct Standards for Swap Dealers and Major Swap Participants
Final Rule Issue Effective Date Compliance Date (Extended)
February 17, 2012 April 17, 2012 May 1, 2013

Business Conduct Standards for Swap Dealers and Major Swap Participants
February 22, 2011

From the comment letter:

"Dodd-Frank does not mandate that the Commission create a “best terms available” standard. The swap markets would be better served if the Commission refrained from creating execution standards that impose survey requirements based upon assumptions of what innovations might occur. In this case, waiting for actual market experience would allow the Commission to determine whether any rule in this area is needed and then to adopt a factually-based principled approach, rather than speculating on how the executed swap market might develop."

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