Comment Text:
Attached please find my submission re: Collection Number 3038-0111"Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants—Cross-Border Application of the Margin Requirements".
My submission is joint to the CFTC and SEC re the above, the CFTC Japan Swap Dealer Capital Comparability Determination, the CFTC Market Risk Advisory Committee and SEC File Number 4-790 (“I seek a rulemaking by the SEC that prohibits a security-based swap dealer or other entity subject to SEC regulation from predicating a security-based swap or other financial instrument subject to SEC regulation on a flip clause, walk-away, or variable subordination.")
I will update and re-submit via the respective portals according to the respective deadlines.
Bill Harrington
Senior Fellow
Croatan Institute
