Swaps Definitions Regulation - Comment Letter - CME Group - July 22, 2011

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Dodd-Frank Timeline, Further Definitions of Swaps, CFTC/SEC
Proposal Date Comment Deadline Final Rule Issue
May 23, 2011 July 22, 2011 Late 2011/Early 2012
Dodd-Frank Timeline, Further Defining “Swap Dealer,” “Major Swap Participant” and “Eligible Contract Participant”
Final Rule Issue Effective Date Compliance Date
May 23, 2012 July 23/Dec. 31, 2012 October 12, 2012

Further Definition of "Swap," "Security-Based Swap," and "Security-Based Swap Agreement"; Mixed Swaps; Security-Based Swap Agreement Recordkeeping
July 22, 2011

From the comment letter:

"...we recommend that the CFTC clarify that nothing in the Release is intended to limit a designated contract market‘s (DCM"s) ability to list for trading as a contract of sale for future delivery any contract regardless of whether that same contract could be characterized as a swap if traded OTC or on a SEF. We further recommend that the Commission clarify that, for purposes of its proposed anti-evasion rules, a market participant may enter into a transaction or structure an instrument or entity to avoid higher regulatory burdens and attendant costs as long as the transaction or entity has an overriding business purpose."



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