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On June 11, 2011, FEI’s Committee on Corporate Treasury joined the Coalition for Derivatives End-Users in filing two comment letters on proposed rules authorized by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The first letter was sent to prudential regulators including the Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC) in response to their “Margin and Capital Requirements for Covered Swap Entities” proposed rule. The second letter was filed with the Commodity Futures Trading Commission (CFTC) in response to their “Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants” proposed rule, RIN 3038-AC97. Both letters urged that regulators should follow congressional intent in exempting end-users from margin requirements in swap transactions.
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