Derivatives Clearing Organizations Regulation - Comment Letter - CBOE Futures Exchange - March 7, 2011

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Dodd-Frank Timeline, DCO,DCM,SEF Conflicts of Interest Mitigation
Proposal Date Comment Deadline Final Rule Proposal
October 18, 2010 June 3, 2011 First Qtr. 2012
Dodd-Frank Timeline, DCO,DCM, SEF Governance Standards, Additional Requirements
Proposal Date Comment Deadline Final Rule Issue
January 6, 2011 June 3, 2011 TBA

DCO, DCM, SEF Governance Standards
March 7, 2011

From the comment letter:

CFE proposes that the CFTC should:

  • "clarify that the only non-member market participants that must agree to become subject to the jurisdiction of a DCM are those non-members of a DCM that have the ability to enter orders directly into a DCM's trade matching system for execution"
  • "clarify the types of significant decisions that a DCM must make public and readily accessible"
  • "apply all of the same governance and transparency requirements to SEFs as are to be applied to DCMs"


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