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Comment Letters & Policy Analysis
New regulatory requirements will have a significant impact on the way companies manage their risks. Chatham has worked closely with the Coalition for Derivatives End-Users – a broad-based coalition of trade associations representing companies that use derivatives to manage risk – to consolidate and communicate end users’ feedback on key issues that affect them. The Coalition’s comment letters, as well as comments from key policy makers and thought leaders, can be found on this page.
Chatham & Coalition Comment Letters
04-02-2012 | EU Chatham Comment Letter on Margin for Uncleared Trades
03-26-2012 | APAC Chatham Response to Monetary Authority of Singapore Consultation on the Proposed Regulation of OTC Derivatives
03-23-2012 | US Coalition for Derivatives End-Users support letter for House Derivatives Bills (HR 2682, HR 2779 and HR 2586)
03-22-2012 | US Chatham Support Letter for HR 2586, The Swap Execution Facility Clarification Act
03-20-2012 | EU Chatham Response to ESMA Discussion Paper “Key concepts of the Alternative Investment Fund managers Directive and types of AIFM”
02-15-2012 | APAC Chatham Clients & Friends Memo, “Assessing Singapore’s Derivatives Regulatory Proposal”
11-10-2011 | US Coalition for Derivatives End-Users letter in support of HR 1650 (Dodd-Frank Improvement Act)
11-10-2011 | US Coalition for Derivatives End-Users letter in support of HR 2779 (Letter in Support of Interaffiliate Swap Exemption)
11-10-2011 | US Coalition for Derivatives End-Users letter in support of HR 2682 (Business Risk Mitigation and Price Stabilization Act)
11-08-2011 | US Coalition for Derivatives End-Users Comment Letter on Implementation Sequencing
07-22-2011 | US Coalition for Derivatives End-Users Comment Letter on CFTC’s Proposed Product Definitions Rule
07-11-2011 | US Coalition for Derivatives End-Users Comment Letter on Prudential Banking Regulators’ Proposed Margin Rule
07-11-2011 | US Coalition for Derivatives End-Users Comment Letter on Proposed Margin Rule
Other Comment Letters
03-29-2012 | US Letter from Chairwoman Stabenow and Chairman Lucas Regarding the Swap Dealer Definition
02-16-2012 | US Response to Senator Crapo on End-User Margin from FDIC Acting Chairman Martin Gruenberg
02-16-2012 | US Response to Senator Crapo on End-User Margin from Fed Governor Daniel Tarullo
02-16-2012 | US Response to Senator Crapo on End-User Margin from Acting Comptroller of the Currency John Walsh
12-10-2011 | EU European Association of Corporate Treasurers Letter to the European Commission
11-09-2011 | US Letter from Senate Banking Committee Chairman Tim Johnson to Various Regulatory Agencies on the Rulemaking Process
07-15-2011 | US Letter from Chairmen Lucas and Conaway to CFTC Chairman Gensler on Rulemaking Process
06-20-2011 | US Letter from Chairmen Stabenow and Lucas to Regulators on Margin, Extraterritoriality and Captive Finance
06-14-2011 | EU Letter from European Parliament’s Werner Langen to US Treasury Secretary Tim Geithner on Scope of Derivatives Legislation
06-13-2011 | US CFTC responses to questions from Capital Markets Subcommittee Chairman Scott Garrett
05-11-2011 | US Letter from Secretary Geithner on End User Margin
Policy Analyses
07-15-2011 | US PPI Policy Brief: The Risks of Over-Regulating End-User Derivatives
