Comment Text:
Meeting with NGX
Tuesday, June 21, 2011
Memo from Preiserowicz, Jacob
NGX
Peter Krenkel
Cheryl Graden
Paul Architzel (WilmerHale)
CFTC
Ananda Radhakrishnan
Sarah Josephson
Phyllis Dietz
Eileen Donovan
Lois Gregory
John Kean
Jonathan Lave
Alicia Lewis
Julie Mohr
Anne Polaski
Jacob Preiserowicz
Additional info:
Participants discussed the proposed rules on DCO financial resources, information management, general requirements, governance, conflicts of interest, risk management, and straight-through processing. The participants discussed the following specific issues, which were also addressed raised in the NGX comment letters: composition of governing boards, use of letters of credit for a guaranty fund and as collateral, daily reporting, settlement banks, fee disclosure, and effective dates.