Comment Text:
Memo from Nadia Zakir
On January 12, 2011, Commission staff participated in a conference call with Jerry Salzman, at Mr. Salzman’s request. The conference call was convened to discuss certain rules proposed in the notice of proposed rulemaking on Core Principles and Other Requirements for Designated Contract Markets (“DCM NPRM”).
The following Commission staff participated in the call: Rick Shilts, Riva Spear Adriance, David Van Wagner, Nancy Markowitz, and Nadia Zakir.
Jerry Salzman was the sole external participant on the call.
During the conference call, Mr. Salzman and Commission staff discussed proposed regulation 38.151 pertaining to the impartial access requirements for members, market participants and independent system software vendors on DCMs. Specifically, Mr. Salzman expressed concerns regarding the impact that the proposed rule may have on the current DCM business model, particularly with respect to the discussion on fee structures. Mr. Salzman also questioned the basis for the proposed rule.
