Comment Text:
Attached please find "SEC File Number 4-790 -- CFTC File for WJH § 13.1 Petition of May 26, 2020 -- October 20 2022".
The submission is joint to the SEC and the CFTC regarding the two title-line matters. Please make the submission publicly available, for instance as the first of "Comments received are available for this petition [SEC File Number 4-790]".
The submission also responds to four additional CFTC matters. I used the respective CFTC portals to file each submission. Please see:
-- "CFTC Japan Swap Dealer Capital Comparability Determination (October 7, 2022)"
(Comments for Orders and Other Announcements 87 FR 48118 - CFTC)
(https://comments.cftc.gov/PublicComments/CommentList.aspx?id=7301);
-- "CFTC Request for Information on Climate-Related Financial Risk (October 7, 2022)"
(Comments for Orders and Other Announcements 87 FR 34856 - CFTC)
(https://comments.cftc.gov/PublicComments/CommentList.aspx?id=7279);
-- "CFTC Market Risk Advisory Committee (October 5, 2022)"
(Comments for Orders and Other Announcements 87 FR 54678 - CFTC)
(https://comments.cftc.gov/PublicComments/CommentList.aspx?id=7314);
and
-- "CFTC Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants—Cross-Border Application of the Margin Requirements Collection Number 3038–0111 (October 4, 2022)"
(https://comments.cftc.gov/PublicComments/CommentList.aspx?id=7300)
(Comments for Public Information Collection 87 FR 48001 - CFTC).
I revised the joint submission for each filing and again for today's distribution. Today's submission of October 20 is complete with respect to all six matters. Each of the earlier submissions is complete with respect to one or more individual matters.
Separately, I thank SIFMA and ISDA for having produced an amicus curiae brief that both quotes my Moody's work extensively and corroborates my submissions.
LehmanBrothers061617.pdf (sifma.org) (https://www.sifma.org/wp-content/uploads/2017/06/LehmanBrothers061617.pdf)
Bill Harrington
Senior Fellow
Croatan Institute
