Summary of FIA’s Comments
FIA believes that the application of LCH's Proposed Rules as they relate to customer property would violate certain regulations of the Commodity Futures Trading Commission. In addition, application of the Proposed Rules as they relate to non-customer property would create undue and potentially unlimited and unquantifiable risk for LCH members. Accordingly, FIA respectfully requests that LCH not adopt the Proposed Rules as drafted.
