Comment Text:
Attached please find my submission re: "Market Risk Advisory Committee”.
My submission is joint to the CFTC and SEC re:
The above;
"CFTC Japan Swap Dealer Capital Comparability Determination;"
"CFTC Collection Number 3038-011'Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants—Cross-Border Application of the Margin Requirements'";
"CFTC Request for Information on Climate-Related Financial Risk";
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 re: "CFTC Japan Swap Dealer Capital Comparability Determination", "CFTC Request for Information on Climate-Related Financial Risk", and "SEC File Number 4-790" via the respective portals on October 7.
I submitted re: "CFTC Collection Number 3038-0111"Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants—Cross-Border Application of the Margin Requirements" on October 4. Please see (https://comments.cftc.gov/PublicComments/CommentList.aspx?id=7300).
Bill Harrington
Senior Fellow
Croatan Institute
