Font Size: AAA // Print // Bookmark

Comment for Proposed Rule 77 FR 43968

  • From: Sheila Bailey-Waddell
    JPMorgan Chase & Co
    BNY Mellon Corp.
    Citigroup, Inc.
    Wells Fargo & Co
    Bank of America Corp
    HSBC North America Holdings
    Goldman Sachs Group, Inc.
    U.S. Bancorp
    PNC Financial Services Group, Inc.

    Comment No: 58827
    Date: 9/24/2012

    Comment Text:

    I am requesting the expediency of a final ruling on this NPR for purposes of identifying the relationship of market participants and their ultimate customers. This request will promote continuous net settlement on open contracts, thus streamlining the clearing process under the PRA (Paperwork Reduction Act.) It is appalling to me that there has not been a process prior to this NPR for disclosure requirements of indentifying beneficial ownership of large trader participants. Many of the large trader participants are existing correspondents by and through their Investment Advisors or Chief Investment officers. Identifying the ultimate customers should be subject to the Right to Financial Privacy Act and recorded as book-entry modifications on the ledgers of existing participants through the Direct Registration System promoting best practices, regulatory compliance and governance. Additionally, this commented proposal would eradicate existing "dark markets" and unsettled trades. The recordation of the ultimate customer(s) or beneficial owners discloses the business relationship with the trader, provides for efficient monitoring of trades and reduces failed trades. Also final ruling of this NPR would disclose to supervisory and regulatory authorities the necessary personally identifiable information necessary for an accurate disclosure of control and statement disclosure information to the intended targets; the ultimate customer (beneficial owner). The existing participants are only agents (designated by their parent organization hierarchies or by the executive agencies of the Federal government). Thus, my reason for identifying the above organizations that are a partial listing of the top 50 bank holding companies. They are the final signaturory authorities pertaining to corporate events of their subsidiaries and other associations; providing official certifications and representations. This list is not intended to be all inclusive.

No records to display.