Swap Entities Regulation - Comment Letter - Morgan Stanley - September 30, 2011

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Dodd-Frank Timeline, Customer Clearing Documentation and Timing of Acceptance for Clearing
Final Rule Issue Effective Date Compliance Date, FCMs, DCMs, DCOs Compliance Date, SEFs
April 9, 2012 October 1, 2012 October 1, 2012 TBA

Customer Clearing Documentation and Timing of Acceptance for Clearing
September 30, 2011

Morgan Stanley explains that their primary concern with the Proposed Rule "is the Commission's intention to impose a blanket prohibition on the use of arrangements that would permit disclosure of the identity of a customer's ESD to its clearing firm, or limit the number of ESDs with whom a customer may trade or the size of swaps executed with a particular ESD that a clearing firm will clear. The Proposed Prohibitions would bar the use of arrangements whereby a clearing firm contractually commits to an ESD to clear specified swaps on behalf of a customer. Morgan Stanley's view is that such contractual arrangements, which include the allocation of so-called sub-limits to ESDs, are critical tools for providing access to the swaps market to all but the largest buy-side institutions, including commercial end-users."


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