LCH.Clearnet: LCH offered its strong support of the policy goals underpinned by the proposed guidance and the statutory provisions contained in Title VII of the Dodd-Frank Act, but made several requests, including that the Commission clarify the reach of the CFTC's clearing mandate when clearing occurs on a registered DCO, and that the Commission reconcile statements in the proposed guidance on the applicability of the swap data repository reporting rules with the actual text of those rules in situations in which two non-U.S. persons (neither of whom is required to register as a swap dealer or

The CFTC has requested comment on a proposed exemption issued in response to a consolidated petition from certain regional transmission organizations (RTOs) and independent system operators (ISOs) to exempt specified transactions from the provisions of the Commodity Exchange Act and CFTC regulations. The Proposed Exemption would exempt the contracts, agreements and transactions for the purchase or sale of the limited electricity-related products which are specifically described within the proposed order from the provisions of the CEA and CFTC regulations, with the exception of CEA Sections 2(a

The NFA announced that, effective September 1, 2012, the following requirements will take effect: Any FCM that makes a withdrawal from its customer segregated funds account(s) or its foreign futures and foreign options customer secured amount funds account(s), which withdrawal is not for the benefit of customers and exceeds 25% of the FCM's residual interest in either such account, must: (i) receive written preapproval from the CEO, CFO, or a listed principal of the firm who holds a position with knowledge of the FCM's financial requirements and position; and (ii) file a written preapproval

ISDA circulated the attached chart, outlining ISDA's schedule for finalizing the "ISDA Disclosure" (standardized general and product-specific risk disclosures), which is being developed to assist with implementation of the disclosure requirements from the CFTC's external business conduct rule (see 77 FR 9734). ISDA is working toward a final publication date of September 15.

The Federal Reserve, the OCC and the FDIC have announced that they are considering changes to the implementation timeline for the annual company-run stress test requirements mandated by the Dodd-Frank Act. Additional details as to the timing for Dodd-Frank stress test requirements will be included in forthcoming final rules. For institutions with between $10 billion and $50 billion in total consolidated assets, which are regulated by these agencies, the changes under consideration would delay implementation until September 2013. Additional Materials: 2012 Banking and Consumer Regulatory Policy