Comment Text:
Dear Mr. & Mrs. C:
Good afternoon and hope all is well way back East.
Please Note: It appears that you all might want to extend your Drop-Dead-Deadline for receiving comments, just a thought. The following are a brief portion of our comments, such as they are:
Abstract: This collection of information involves the financial resource reporting requirements set forth in section 39.11 of the Commission’s regulations. Section 5b(c)(2) of the Commodity Exchange Act (‘‘CEA’’ or ‘‘Act’’) 2 sets forth certain core principles with which a derivatives clearing organization (‘‘DCO’’) must comply in order to become registered with the Commission and to maintain such registration. One of these core principles, core principle B, sets forth the financial resource requirements applicable to DCOs. Section 5b(c)(2) also requires DCOs to comply with the regulations promulgated by the Commission pursuant to section 8a(5) of the Act.3 Section 39.11 of the Commission’s regulations, which implements core principle B, includes the financial resource reporting requirements that are the subject of this information collection. The information collection is necessary for, and would be used by, the Commission to evaluate a DCO’s compliance with the financial resource requirements for DCOs prescribed in the CEA, including core principle B, and the Commission’s regulations.
Who, other than the entities conducting their business within the ‘regulations’ of the CEA review, test, analyze, verify the accuracy and efficacy of the data they submit, just to be sure they’re not committing fin fraud, (aka: Financial Fraud, as happened way back in 1989, ((aka: CDO’s, CDS’s, Bear Stearns, Lehman Brothers, AIG, et cetera))? .Or, do we just accept whatever they send you all, and three years later we discover what was submitted was tainted…. (Plusss, it’s French for +) Due to the passage of The Jobs Act Tax Cut Bill-2017, this is all a tad premature due to the fact that the following regulatory agencies are undergoing an extensive clarification, updating and re-writing multiple business functional and natural/business mgt. (aka: the C-Suite gentlemen must address to satisfy their GRC (Governance, Risk & Compliance) obligations rules, regulations and compliance tax artifacts.) Secondly, we’d like to see the test results and reports from your extensive outreach program to those entities impacted by your decisions including; auditors, cpa’s, investment community, investment industry, regulators and those chosen to provide the ‘Reasonable Man’ litmus test for your efforts. This process at this point in time is being conducted by some of the following regulatory agencies; FASB, PCAOB, AICPA, et cetera….And lastly, we applaud your efforts to broadcast far and wide your announcements seeking comments from your clients, customers, stakeholders and constituents by burying same at the bottom of the ‘Black-hole of Calcutta’….(aka: The Federal Register), is it possible there is any connection with the dearth of comments received over and over and over and….lack there-of any comments what-so-ever received by the regulatory agencies including the CFTC et al?
Also, the following must be an extended typo by someone, somewhere but please don’t punish them as it’s only part and parcel of the ‘Human Factor’ which leads to airline maintenance screw-ups leading to airline disasters, et al and subjective interpretations of regulations that should be formulaic, as in without room for interpretation:….” … There are no capital or start-up costs associated with this information collection, nor are there any operating or maintenance costs associated with this information collection….” This has to be a typo, since we all know, whenever there is a change in anything, including regulations, there are associated costs in getting up to speed, without the requisite number of glitches tossed in…
Perhaps. Lastly, please correct the respective gobble-de-gook content verbage currently found within each Federal Register Announcement seeking a Request for Comments---to bad there hasn’t been any technical advancements since the establishment of the GPO (Government Printing Office), yep, too bad really. Also, we’d prefer something a bit more clear than an exercise in the proper use of semi-colons, hyphens and dangling participles. Don’t you agree? Lastly, lastly, please offer us your walk-throughs and testing results so we all can review them, repeat them and be satisfied that a rogue-subjective-tool-head had not obfuscated the data provenance of same….Just so we can verify for ourselves the efficacy of what we’re being presented with…..One final reminder….Please Note: We’re the current victim of invisible cows being able to hack into my laptop, rendering our my normal civility totally useless---we believe they’re Guernsey repatriates skilled in programming in mud, while remotely working for Face-de-Bookends---living in the tiny border-less country of Ebola, in Eastern Europe---but we’re not sure. We hope you all will accept our solo-comments with the same grace and interest as they were delivered, as we believe you all are conducting important stuff. Respectfully yours, Pw Carey
