The Chamber supports efforts to bring transparency to the over-the-counter (OTC) derivatives market and to implement measures aimed at reducing systemic risk while preserving the ability of business end-users to use customizable OTC derivatives at a reasonable price and without the burden of margin requirements. In addition, end-users should be protected from onerous bank-like regulation that would divert precious working capital
- Enact legislation that would exempt non-financial end-users from onerous, costly, and unnecessary margin requirements, consistent with the Congressional intent when Dodd-Frank was passed.
- Ensure that purely internal, inter-affiliate derivatives transactions are exempt from clearing, margin, and other requirements more appropriately applied to market-facing swaps, consistent with the Congressional intent when Dodd-Frank was passed.
- Clarify that non-financial companies that use centralized treasury units to hedge risk will be eligible for the end-user clearing exception.
- Limit the extraterritorial reach of domestic derivatives regulation to ensure U.S. dealers are not disadvantaged overseas and to ensure that Main Street non-financial companies’ cross-border counterparty relationships are not undermined by overlapping regulation.
CCMC is an active member of the Coalition for Derivatives End-Users. More than 270 companies and business associations have joined the Coalition in seeking strong, effective and fair regulation of derivatives markets. www.coalitionforderivativesendusers.com