Swaps Review Regulation - Comment Letter - LCH.Clearnet 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

According to the comment letter, LCH.Clearnet Group:

  • "believes it is critically important that the Commission establishes a process for the review and designation of Security-Based Swaps for mandatory clearing and, equally, that it subjects market infrastructures to strict requirements to ensure their safety and robustness;"
  • "believes that the process set out in the Proposing Release is consistent with the Congressional requirement that a clearing agency be eligible to clear Security-Based Swaps, and that before a Security-Based Swap becomes subject to mandatory clearing, the public get to provide input on the contract or class of contracts;" and
  • sets forward additional comments under specific categories, listed below.
  1. The eligibility of a clearing agency to clear security-based swaps.
  2. The submission of security-based swaps to the Commission for review.


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