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Comment for Orders and Other Announcements 85 FR 22724

  • From: Bill Harrington
    Harrington Independent Flip Clause Assessments

    Comment No: 62638
    Date: 5/26/2020

    Comment Text:

    See PDF-file for the submission of Bill Harrington (Harrington Independent Flip Clause Assessments), which is joint to the Secretariat and to the GMAC Subcommittee on Margin Requirements for Non-Cleared Swaps.
    The joint theme: The CFTC Must Eradicate the Flip Clause and the Flip-Clause-Swap-Contract!
    To the Secretariat: This is a § 13.1 Petition for a Rule that Bars an Entity from Agreeing to a Flip Clause or Walk-Away.
    To the GMAC Subcommittee: Clear-sighted regulation of derivative contracts is vital to the well-being of our Country. The Commission must respect above all else the well-being of US human beings and the preservation of the US financial system.
    Deference a joke given our pre-eminence in derivatives, which will grow post-BREXIT.
    The CFTC must restrict “international comity and deference” to the proper spheres, e.g., when Chair Emeritus Giancarlo next attends a Downton Abbey tea party or beseeches His Holiness to beatify credit default swaps with flip clauses.