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External Meetings: Remarks to ISDA Board Meeting

When:
11/17/2010 1:00 PM
Rulemaking(s):
II. Definitions

VII. DCO Core Principles

VIII. Process for Review of Swaps

XIV. FBOT Registration

XVII. Data Recordkeeping

XVIII. Real Time Reporting

CFTC Staff:
Gary Gensler

Timothy Karpoff
Visitor(s):
Michael Aktipis, Cleary, Gottlieb, Steen & Hamilton

Warren Allen, Skadden, Arps, Slate, Meagher & Flom LLP

Jon Ammons, Winston & Strawn LLP

Adam Arkel, FINRA

Geoffrey Aronow, Bingham McCutchen LLP

Pragati Salsawer, Federal Housing Finance Agency

Nazanin Baseri

Ann Battle

Sarah Bianchi

Romkaew Broehm

Michael Brooks, Sutherland

Ashley Burden

James Cain, Sutherland

Monica Campbell

Brian Castro

Robyn Cincotta

Martha Clarke, Office of Thrift Supervision

Margaret Claybour, Winston & Strawn LLP

Christine Cochran, Commodity Markets Council

Gordon Coffee, Winston & Strawn LLP

Walter Conner, Sutherland

Ken Connolly, Goldman Sachs

Donald Dankner, Winston & Strawn LLP

Christopher Donahue, Oblon Spivak McClelland Maier

Maureen Donley, Skadden, Arps, Slate, Meagher & Flom LLP

Emily Duncan, Winston & Strawn LLP

Wells Engledow, Fannie Mae

Christopher Fain

George Fatula, Bracewell & Giuliani LLP

Jonathan Flynn, McDermott Will & Emery

Danielle Fortier

Michael Fox, Federal Home Loan Mortgage

Kevin Freeman

Tyler Gellasch, U.S. Senate

Gary Goldsholle, FINRA

Heather Harker, Dykema Gossett PLLC

James Harshaw, GM Asset Management

Barry Hart, Winston & Strawn, LLP

Megan Henry

Edward Horahan, Edward B. Horahan III, PLLC

Dominic Hulse

Umesh Jani

Sanjeev Joshipora, Commodity Markets Council

Eric Kadel, Sullivan & Cromwell LLP

Amadou Kilenny Diaw, Winston & Strawn LLP

Kathy Koneiczny, Winston & Strawn

Catherine Krupka, Sutherland

Matthew Kulkin, Patton Boggs

Eric Lashner, Hogan Lovells US LLP

Ernest Lee

Jay Levine, Winston & Strawn LLP

Patrick Linehan, Steptoe & Johnson LLP

Alonzo Llorens, Nelson Mullins Rilery & Scarborough LLP

Julie Loeser

Lorna MacLeod, Dewey & LeBoeuf LLP

Peter Malyshev, Winston & Strawn LLP

Kent Mason, Davis & Harman LLP

Jai Massari, Willkie Farr & Gallagher LLP

Charles Mills, Kirkpatrick & Lockhart Preston Gates

Thomas Mills, Winston & Strawn LLP

Mitchell Naumoff, Jones Day

Theresa Nguyen, Arnold & Porter LLP

Matthew O'Leary

Kathleen O'Mara, FINRA

Wemi Peters, Winston & Strawn LLP

Owen Pinkerton, Sutherland

Daniel Porter, Winston & Strawn LLP

Aquila Powell, GM

Raymond Ramirez

Carolina Romero Acevedo

Bella Sanevich

Mary Scholten

Elena Schwieger, WilmerHale

Eric Silva, Winston & Strawn

Jose Sosa, Fiddler Gonzalez & Rodriguez

Nicole Soukup, Winston & Strawn LLP

Frank Sudia

Sarah Swanz, Richards Kibbe & Orbe LLP

Mary Wall, Winston & Strawn LLP

Craig Wasserstrom

Mark Young, Skadden, Marps, Slate Meagher & Flom LLP

Evan Zebooker, Markit

Luke Zubrod, Chatham Financial

 

Monica Campbell
Organization(s):
DC Bar Association Members
  • The Chairman opened the meeting by giving a description of the rulewriting process and how the Commission has organized itself around 30 teams. He then informed the attendees of the status of the process and what rules were yet to be considered. Following the update, the Chairman asked for questions.~ ~The first question concerned the possibility for a phase-in approach to the imposition of new rules coming out of Dodd-Frank. The potential phase-in would apply in particular to clearing, reporting, and trading rules. With respect to clearing rules, the questioner suggested that the phase-in might be based on the participants in the transaction (dealer to dealer; dealer to MSP; dealer to end-user) or perhaps based on the asset class of the instrument. With respect to reporting rules, the questioner suggested that the phase-in might occur first in cleared and exchange traded products, then in cleared but not exchange traded products and, then finally, in the bilateral products. Finally, the questioner suggested that trading requirements should be phased-in first for the most liquid instruments. The Chairman agreed to take this under advisement.~ ~The second question concerned the prudential regulation of clearinghouses. Specifically, the questioner asked about governance requirements with respect to membership on CCPs' risk committees. In addition, the questioner asked about membership eligibility standards and how that might affect the soundness of the clearinghouse. Finally, the questioner suggested that CCPs should have financial resource requirements that require them to be able to withstand the failure of their two largest members, not just their largest. The questioner endorsed membership criteria that would be scalable in relation to the potential members' capital and financial resources.~ ~The third set of questions concerned reporting requirements. The questioner was, in particular, concerned with how block trades would have to be reported. Specifically, he focused on the delay before reporting, to allow the dealer to hedge the trade, and the specificity of the reporting, so that other market participants would not be able to figure out another's position. The questioner suggested that this issue loomed largest in credit markets.~ ~The last set of questions concerned extra-territoriality. The questioner was interested in the degree to which the Commission would regulate the businesses of foreign entities that registered as swap dealers. He was concerned that conflicts might arise between the Commission and the foreign registrant's home country regulator.

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