FIA President John Damgard discussed some of the adverse consequences of the extraterritorial impact of the Dodd-Frank Act at a May 25 hearing of the House Agriculture Committee’s subcommittee on general farm commodities and risk management. Damgard focused on two specific examples: the financial and operational burdens caused by the requirement that foreign clearinghouses register with the CFTC in order to clear swaps traded by U.S. counterparties, and the costs of a position limit regime in U.S. markets that is not matched in other jurisdictions. Damgard also raised an issue with the rulemaking process as a whole, urging the CFTC to provide a 60-day comment period on the entire “mosaic” of proposed rules before they are finalized.
