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Comment for Proposed Rule 75 FR 76573

  • From: Ex Parte Communication
    Sam Peterson
    Joe Siu
    Miriam Steinberg

    Comment No: 27295
    Date: 1/21/2011

    Comment Text:

    Conference call with Chatham Financial

    Friday, January 21, 2011

    Memo from
    Leonova, Irina

    CFTC Staff :
    Irina Leonova
    David Taylor

    External Attendees :
    Sam Peterson
    Joe Siu
    Miriam Steinberg

    Additional Information :
    The potential burden of reporting all ISDA terms and lack of benefit commensurate with it
    Cases where end-users could potentially be the reporting entities:
    - U.S. end-users entering into transactions with foreign swap dealers
    - Inter-affiliate transactions under the same corporate umbrella (centralized treasury)
    - Frequency and reporting burden if end-users were the reporting entities
    - Particularly, how collateral would have to be reported
    - Daily frequency would be difficult for the lack of existing infrastructure and cost of implementing new infrastructure

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