Derivatives Clearing Organizations Regulation - Comment Letter - Eurex Clearing - December 13, 2010

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Dodd-Frank Timeline, Financial Resources Requirements for Derivatives Clearing Organizations
Proposal Date Final Rule Issue Effective Date
December 13, 2010 October 18, 2011 January 9, 2012

Financial Resources Requirements for Derivatives Clearing Organizations
December 13, 2010

From the comment letter:

Eurex Clearing believes that the proposals “will not inhibit competition among clearinghouses; if adopted as proposed, the rules will help assure that DCOs have the resources to withstand substantial defaults and continue operations for a period of time under adverse circumstances. While Eurex Clearing supports adoption of the Commission’s current proposal, it encourages the Commission to continue to align its proposal with that of the Committee on Payment and Settlement Systems and the International Organization of Securities Commissions which is currently under review… The Commission further proposes that DCOs be required to have sufficient resources to enable them to continue operating for at least one year. Eurex Clearing agrees that this having such a requirement is reasonable, especially in view of the flexibility implied in the Commission’s proposed rules for types of financial resources, but cautions that the one year time frame may be unnecessarily long.”



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