Swap Entities Regulation - Comment Letter - BlackRock - April 11, 2011

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Dodd-Frank Timeline, Requirements for Processing, Clearing, and Transfer of Customer Positions
Proposal Date Final Rule Issue Effective Date
December 13, 2010 October 18, 2011 January 9, 2012

Requirements for Processing, Clearing, and Transfer of Customer Positions
April 11, 2011

From the comment letter:

  • "The CFTC should not require that a swap executed on a SEF or DCM be submitted for clearing immediately."
  • "Futures and swaps have different risk profiles, so the futures model for trade allocation is not appropriate for cleared swaps."
  • "To accommodate the post-trade execution allocation process that is critical to allowing asset managers to service their clients effectively, and to account for the different risk profile between OTC swaps and futures, we recommend that the CFTC's final rules provide that:
    • at time of trade execution, confirmation of the trade's economic details is done at the block level removing uncertainty of market risk elements of the trade; and
    • for submission of clearing of the trade to a DCO a delay of up to 2 hours be allowed."



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