Volcker Rule - CFTC - Comment Letter - Futures Industry Association - April 16, 2012

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Dodd-Frank Timeline, "Volcker Rule," CFTC
Proposal Date Comment Deadline Final Rule Released
February 14, 2012 April 16, 2012 December 10, 2013

Volcker Rule - CFTC
April 16, 2012

In their comment letter to the CFTC, FIA recommends the following:

  • exclude forwards and contracts and other physically settled contracts from the definition of covered financial position;
  • exclude foreign exchange forwards and swaps from the definition of derivative;
  • include in the scope of permissible government obligation activities transactions in futures and swaps on U.S. government obligations;
  • include in the scope of permissible government obligation activities transactions in foreign sovereign debt and in futures and swaps on those obligations; and
  • include only those commodity pools and foreign funds in the definition of “similar funds” that are, in fact, similar to hedge funds or private equity funds

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