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Comment for Proposed Rule 87 FR 53832

  • From: Deep Mangat
    Mangat Analytics

    Comment No: 69733
    Date: 9/22/2022

    Comment Text:

    I believe updating the reporting rules, as proposed, may improve the CFTC's ability to assess
    potential systemic risks due to a portfolio's concentration in a directional trade. However, I feel a portion of the proposal (as quoted below) may have unintended consequences in constraining market liquidity if the time frame of the exposure were to be less than one day or within one trading week.

    "The proposal also would require qualifying hedge funds to identify all
    other counterparties (by name, LEI, and financial institution
    affiliation) to which a fund has net mark-to-market exposure after
    collateral that equals or is greater than either (1) five percent of a
    fund's net asset value or (2) $1 billion and would require these
    advisers to report the amount of the exposure before and after
    collateral posted by either the counterparty or the reporting fund as

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