Comment Text:
Phone call with representatives of the Futures Industry Association (FIA) regarding proposed Regulation 39.12(b)(4)(ii)
Monday, March 14, 2011
Memo from
DeBord, Jon M
CFTC Staff :
John Lawton, Phyllis Dietz, Anne Polaski
External Attendees :
Kevin Foley (Katten Muchin Rosenman LLP); Maria Chiodi (Credit Suisse); Bonnie Litt (Goldman Sachs & Co.); David Sturm (JP Morgan Futures, Inc.); and Lou DiCerbo (Bank of America Merrill Lynch)
Additional Information :
On March 14, 2011, at 5:00 p.m. EDT, staff of the CFTC Division of Clearing and Intermeidary Oversight (DCIO) and representatives of the FIA participated in a conference call at the request of FIA. The topic was the novation provision set forth in proposed Regulation 39.12(b)(4)(ii). To the extent that the proposed rule text may be ambiguous, the FIA was invited to submit a written comment with suggested revised language.
