FEI committees: COT weighs in on Dodd-Frank.

• Position: FEI NEWS - Financial Executives International

Long before the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 was enacted, FEI's Committee on Corporate Treasury (CCT) began actively monitoring proposals to regulate over-the-counter (OTC) derivatives markets along with other end users who utilize these markets in their risk management activities. Now that the Dodd-Frank act has been signed into law and federal rule-makers are busy issuing rules to implement its provisions, CCT continues to weigh in with both regulators and Congress to ensure that end users can continue to mitigate their business risks in a manner that is not unduly burdensome.

Most recently, FEI staff joined the Coalition for Derivatives End-Users in meeting with staff from the Commodity Futures Trading Commission and U.S. Securities and Exchange Commission to discuss a comment letter CCT signed on providing clear exceptions for end users from new derivatives requirements.

As stated in the letter, regulators need to issue an unambiguous exemption for end users from clearing, margin and capital requirements to ensure that these companies may continue to efficiently manage their risks and invest in the U.S. economy to create jobs. Furthermore, these companies did not cause the financial crisis and do not pose systemic risk, which is what Dodd-Frank is, at least in part, intended to mitigate.

Additionally, on April 8, CCT joined several other organizations in sending a letter to Congress expressing concern with the short timeline for rulemaking in the wake of Dodd-Frank since federal agencies must write more than 200 rules, mostly within a year.

The letter states that "while we recognize the need to establish a derivatives...