Comment Text:
JSCC should be exempt from DCO Registration as their clearing platform is probably superior to the CFTC one by a decade or so. CFTC can then take notes from JSCC on how to enforce a proper clearing.
But it is important that the JSCC show how their clearing works and how it complies with CFTC mandates. If it can do that sufficiently, there is no practical reason for them to duplicate their efforts with additional registration which would add costs and overhead to market participants.
