Swaps Review Regulation - Comment Letter - Americans for Financial Reform - February 14, 2011

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Dodd-Frank Timeline, Process for Review of Swaps for Mandatory Clearing; Technical Amendments, SEC
Final Rule Issue Effective Date Compliance Date
June 28, 2012 August 13, 2012 December 10, 2012

Process for Submissions for Review of Security-Based Swaps for Mandatory Clearing and Notice Filing Requirements for Clearing Agencies
February 14, 2011

In the comment letter, AFR:

  • "urge[s] the Commission to require clearing agencies to disclose detailed information about the swap or class of swaps it proposes to clear – and also to require the submission of publicly available information regarding the reasons why the clearing organization rejects a given swap or class of swaps for clearing;"
  • "urges the Commission to include in the final rule the proposals that would allow for public comment on a clearing agency’s Security-Based Swap Submission and prevent evasion of the clearing requirement;" and
  • "believes the Commission should avoid excessive dependence on private external validators for assessing the core elements in a Security-Based Swap submission, and should draw on the range of available data and technical expertise represented among the members of the Financial Stability Oversight Council (FSOC) in assessing the effects of clearing and performing market surveillance."


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