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Better Markets Inc. Letter on Exemption from Derivatives Clearing Organization Registration (RIN 3038-AE65) (November 22 2019)

Better Markets filed this comment letter on the Commodity Futures Trading Commission’s (CFTC) supplemental notice of proposed rulemaking setting forth multiple new clearing-related exemptions.  Better Markets objected, in particular, to two primary exemptions in the proposal:  (1) the exemption from derivatives clearing organization registration and related requirements for certain non-U.S. clearing organizations; and (2) the exemption from futures commission merchant registration and related requirements for non-U.S. persons accepting U.S.