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       Posted on October 12th, 2011

FIA Comment Letter on FCM Risk Management

The Futures Industry Association submitted a comment letter on Sept. 29 responding to the Commodity Futures Trading Commission’s proposed Rule 1.73, which would require clearing member FCMs to adopt and implement comprehensive risk management policies and procedures. The FIA said it has long been a proponent of strong risk management practices but questioned [...]


       Posted on October 9th, 2011

FIA and ISDA Comment on CFTC Clearing Documentation Proposal

The Futures Industry Association and International Swaps and Derivatives Association filed a joint comment letter on Sept. 30 responding to a proposed rule issued by the Commodity Futures Trading Commission regarding documentation for cleared swaps and the timing of acceptance or rejection of trades for clearing by derivatives clearing organizations and clearing members. [...]


       Posted on September 18th, 2011

Trade Associations letter to U.S. Regulators on Treatment of Inter-Affiliate Transactions under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act

The FIA joined with six other U.S. financial trade associations in filing a joint letter on the treatment of derivatives trades involving two affiliates of the same organization under the Dodd-Frank Act. The Sept. 8 letter described how inter-affiliate swaps are used by financial institutions and customers and urged the regulators to limit [...]


       Posted on September 6th, 2011

FIA / ISDA / SIFMA joint comment on the SEC proposed rules regarding business conduct standards for dealers and major participants in the security-based swaps market

The FIA joined with two other trade associations (ISDA and SIFMA) in filing a joint comment on the Securities and Exchange Commission’s proposed rules regarding business conduct standards for dealers and major participants in the security-based swaps market. This letter, which was filed on Aug. 26, noted that the Commodity Futures Trading Commission [...]


       Posted on July 18th, 2011

Trades Groups Comment Letter on Capital Requirements for Swap Dealers and MSPs

The FIA joined with the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association in filing a comment letter with the Commodity Futures Trading Commission on July 7 regarding the agency’s proposed capital requirements for swap dealers and major swap participants. The letter expressed support for those aspects of [...]


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