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Comment for Proposed Rule 75 FR 51429

  • From: Ex Parte Communication
    Organization(s):
    Credit Suisse

    Comment No: 42256
    Date: 4/15/2011

    Comment Text:

    Meeting with Credit Suisse

    Friday, April 15, 2011

    Memo from
    Banerjee, Anuradha

    CFTC Staff :
    Jacqueline H. Mesa
    Aaron Miller
    Anuradha Banerjee

    External Attendees :
    Lisa Rabbe (Credit Suisse)
    John A. Anderson (Credit Suisse)

    Additional Information :
    Credit Suisse is interested in understanding the cross-border application of Dodd-Frank.  Which foreign firms will need to register as swap dealers?  Credit Suisse emphasized that the risks of delocation is the highest right now.  Credit Suisse also indicated that the comments put forth in the IIB and Davis Polk letters are in line with Credit Suisse's comments.  
     
    With regard to common data IDs for traders, Credit Suisse understands that they will be very expensive, but the industry thinks that it is very important to match things up.  Credit Suisse's head of security wants unique IDs because unique IDs will make "huge difference" for transparency.  Credit Suisse would like the IDs to be in place before reporting begins because it will be expensive to go in later and change the systems.

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