Foreign Boards of Trade Regulation - Comment Letter - London Metal Exchange - January 14, 2011

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Dodd-Frank Timeline, Registration of Foreign Boards of Trade
Final Rule Issue Effective Date Compliance Date
December 23, 2011 February 21, 2012 August 20, 2012

Registration of Foreign Boards of Trade
January 14, 2011

From the comment letter:

"...the LME believes that the CFTC could achieve the objectives it has identified for the Proposed Rules with a comparability based exemptive approach that would be significantly less burdensome for applicants and Commission staff and that would be more consistent with existing frameworks for the regulation of cross-border market access. Specifically, the LME recommends that the Commission:

  • make jurisdiction-by-jurisdiction comparability analyses with respect to exchange and clearinghouse regulation and delete these elements from the application materials; and
  • adopt an exemptive rather than registration regime, consistent with international practice, and require contract designation (as in the case of US DCMs) only with respect to linked contracts (involving US-centric commodities).


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