Swaps Regulation - Cross-Border Application - Comment Letter - CME Group - August 27, 2012

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Dodd-Frank Timeline, Cross-Border Application of Swaps Provisions, CFTC
Proposal Date Comment Deadline Compliance Extension Guidance Effective Date
July 12, 2012 August 27, 2012 July 12, 2013 July 26, 2013

Cross-Border Proposed Interpretive Guidance
August 27, 2012

From the comment letter:

"Although through central counterparty clearing, the credit of the clearing house is substituted for the credit of each counterparty through the novation process, a clearing house is not a "counterparty" as contemplated by these definitions. To treat the clearing house as a "counterparty" within the meaning of a SD and/or MSP would render every person who clears an SD under DFA and commission regulations. Congress did not intend such an extreme result."



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