Comment Text:
See PDF-file for the submission of Bill Harrington (Harrington Independent Flip Clause Assessments), which is joint to the Secretariat and to the GMAC Subcommittee on Margin Requirements for Non-Cleared Swaps.
The joint theme: The CFTC Must Eradicate the Flip Clause and the Flip-Clause-Swap-Contract!
To the Secretariat: This is a § 13.1 Petition for a Rule that Bars an Entity from Agreeing to a Flip Clause or Walk-Away.
To the GMAC Subcommittee: Clear-sighted regulation of derivative contracts is vital to the well-being of our Country. The Commission must respect above all else the well-being of US human beings and the preservation of the US financial system.
Deference a joke given our pre-eminence in derivatives, which will grow post-BREXIT.
The CFTC must restrict “international comity and deference” to the proper spheres, e.g., when Chair Emeritus Giancarlo next attends a Downton Abbey tea party or beseeches His Holiness to beatify credit default swaps with flip clauses.
