Comment Text:
Conference call with Chatham Financial
Friday, January 21, 2011
Memo from
Leonova, Irina
CFTC Staff :
Irina Leonova
David Taylor
External Attendees :
Sam Peterson
Joe Siu
Miriam Steinberg
Additional Information :
The potential burden of reporting all ISDA terms and lack of benefit commensurate with it
Cases where end-users could potentially be the reporting entities:
- U.S. end-users entering into transactions with foreign swap dealers
- Inter-affiliate transactions under the same corporate umbrella (centralized treasury)
- Frequency and reporting burden if end-users were the reporting entities
- Particularly, how collateral would have to be reported
- Daily frequency would be difficult for the lack of existing infrastructure and cost of implementing new infrastructure
