Global Correspondence

GFMA Submits Comments to the CFTC on the CME Group Proposal to Require Reporting of All Swaps Cleared with the CME SDR

The Global Foreign Exchange Division (GFXD) of GFMA provides comments to the U.S. Commodity and Futures Trading Commission (CFTC) on on the proposal made by the Chicago Mercantile Exchange Inc. (CME) in its amended submission # 12-391R dated December 6, 2012, which requests the CFTC to approve of a new Chapter 10 and Rule 1001 (the Proposed Rule) of the CME’s Swap Data Repository (SDR) rulebook.

GFMA believes that the CFTC should not approve the Proposed Rule for multiple reasons, including that the Proposed Rule, which would require all swaps cleared with the CME to be reported to the CME’s SDR, violates the “fair and open access” principle of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

GFMA emphasizes
that the concerns raised in this letter are not exclusive to the CME and the
Proposed Rule, but apply generally to any designated clearing organization (DCO)
that seeks to require all swaps cleared with it to be reported to a specific swap
data repository (SDR). 

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