Comment Text:
I mostly agree with what this sets out to do, but I have an issue with two parts of the rule.
39.15(h) - Exemptions for Foreign DCOs
and
39.15(b)(3) - Holding Customer Funds at Central Banks:
39.15(b)(3) should supersede 39.15(h). Exemptions only open up the possibility and likelihood of abuse, therefore no exceptions, such as 39.15(h), should exist. The rule in question pertains to American markets regulated by an American agency, and multi-national companies should adhere to the actual rule intended by the CFTC.
To add, I believe 39.15(g) should be more strict. It currently states that the CFTC should only be notified in the event of discrepancies, but I believe the CTFC should be more thoroughly involved with the DCO's reports and reconciliations.
