External Meetings: Meeting with Banks

External Meetings: Meeting with Banks

The meeting discussed the application of Dodd-Frank Act requirements, particularly to cleared swaps, including the timing of implementation of various requirements.  Citi, Morgan Stanley and JP Morgan expressed the view that a clearing mandate should be applied after a critical mass of dealers are ready to clear swaps for clients, and that differentiated margin requirements for uncleared swaps should apply only after clearing is mandated and is well underway.  Citi, Morgan Stanley and JP Morgan also expressed the view that the Dodd-Frank Act requirements should not necessarily appl

External Meetings: Evolution Markets

External Meetings: Evolution Markets

Participants discussed the proposed product definitions rulemaking, and in particular the scope of the forward contract exclusion.  Evolution took the position that the rulemaking should clarify that cleared forwards between commercial participants should be permitted under the forward contract exclusion.  Evolution Markets also believes that emission allowances should qualify as nonfinancial commodities.