Joint Trade Association Letter in response to the recent DOJ Letter on Ownership and Governance of Clearing Entities
Multiple trade associations sent a letter to respond to the letter submitted by the DOJ staff on December 28, 2010 to the CFTC regarding the Proposed Rules.
The letter proposes that Dodd-Frank's mandatory clearing and execution requirements accentuate the importance of competition and innovation among and by DCOs, DCMs, and SEFs and that the views expressed by DOJ staff appear to represent a significant departure from the DOJ's experience and writings on this subject and ignore the DOJ's antitrust analysis of the structural restraints on competition that are endemic to a vertically integrated exchange-clearing market.
Date
January 11, 2011
Cross References (links may require a Cabinet subscription)
75 Fed. Reg. 33752