The Commodity Futures Trading Commission (CFTC) has proposed a
series of changes to its general regulations governing derivatives
clearing organizations (DCOs).1 The CFTC has stated that
the proposed amendments are intended to enhance certain risk
management and reporting obligations, clarify certain provisions,
simplify registration and reporting processes and codify existing
relief and guidance, consistent with the objectives of Project
KISS,2 the CFTC’s initiative to simplify its
regulations and reduce costs for market participants. However, many
of the proposed amendments would require significant changes to
current practice and impose new obligations for DCOs (and their
clearing members), and are not merely in the nature of
clarifications, clean-up and codification of staff positions.
