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2010 OCC Comment Letters

CFTC, December 10, 2010
RIN 3038-AC98 Financial Resources Requirements for Derivatives Clearing Organizations
OCC submitted this letter in response to the CFTC's request for comment on its proposed rules that would establish financial resources requirements for DCOs for the purpose of ensuring that they maintain sufficient financial resources to enable them to perform their functions in compliance with Dodd-Frank. View Agency Release.

SEC, November 22, 2010
S7-27-10 Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies Under Regulation MC
OCC submitted this letter in response to the SEC's request for comment on its proposed rules for mitigating conflicts of interest at registered securities clearing agencies that clear security-based swaps, security-based swap execution facilities, and national securities exchanges that list security-based swaps for trading. OCC's comments are limited to those aspects of the proposed rules that affect security-based swap clearing agencies. The proposed rules are similar to the conflict of interest rules proposed by the SEC and we applaud the efforts of the two agencies to coordinate their rulemaking activities in this area. View Agency Release.

CFTC, November 17, 2010
3038-AD01 Requirements for Derivatives Clearing Organizations Regarding the Mitigation of Conflicts of Interest
OCC submitted this letter in response to the CFTC's request for comment on its proposed rules for DCOs, designated contract markets and swap execution facilities regarding the mitigation of conflicts of interest. The proposed rules are being promulgated in response to the mandate of Dodd-Frank. OCC's comments are limited to those aspects of the proposed rules that affect DCOs. The proposed rules are similar to rules recently proposed to the SEC and OCC applauds the efforts of the two agencies to coordinate their rulemaking activity. This letter is similar to the letter sent to the SEC on the same issue. View Agency Release.