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