Swaps Review Regulation - Comment Letter - CME Group - 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

From the comment letter:

  • "The Commission should limit the breadth of the submission required by a clearing agency seeking approval to clear a security-based swap to addressing whether clearing such a security-based swap comports with the Exchange Act Section 17A."
  • "CME requests that the Commission not require clearing agencies to perform an analysis of the 3C(b)(4)(B) factors or factors related to open access in its submission for permission to clear a security-based swap. Rather, the Commission should require a clearing agency to address only its ability to clear the swap at issue while continuing to comply with Section 17A in its submission for approval to clear a security-based swap."


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