The Coalition believes Congress communicated repeatedly both throughout the legislative process and in the text of the Dodd-Frank Wall Street Reform and Consumer Protection Act that end-users should not be subject to margin requirements.
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As the Coalition explained in its previous letter responding to Treasury’s request for comments regarding a potential exemption for FX swaps and forwards, the FX market has pioneered the adoption of more transparent electronic trading platforms.
June 6, 2011
The legislation would help ensure that political spending—or the lack thereof—continues to play no role in federal contracting decisions.
In addition, the Commission is given authority to promulgate rules that are “reasonably necessary to prohibit the trading practices described in paragraph (5) and any other trading practice that is disruptive of fair and equitable trading.”
However, we are concerned that regulators need more time to analyze, write, and implement functional rules that will help stabilize the OTC derivatives market, not damage it.
May 5, 2011
The Coalition has been actively engaged in the legislative process that culminated with passage of the Dodd-Frank Act and with the bill’s implementation.
The Coalition believes proper documentation of swap transactions is important to ensure that both parties to a transaction agree on its terms.
While we recognize the need to establish a derivatives regulatory regime quickly, it is more important that it be established correctly.
March 11, 2011
The Coalition has long supported an approach that focuses regulatory requirements on market participants that have the potential to pose risk to the financial system.
The Conflict Minerals Provision applies to issuers for whom conflict minerals are “necessary to the functionality or production of a product.”
The numerous rules proposed thus far indicate that swap dealers, security-based swap dealers, and major participants will have to invest significant amounts of time and resources to comply with the new regulatory regime.
The Coalition seeks to ensure that financial regulatory reform measures promote economic stability and transparency without imposing undue burdens on derivatives end-users.