January 17, 2013
Comment: COMMENTS ON PROPOSED RULES, REGULATIONS OR AGENCY ACTIONS:
Your notice indicated that “The Commission has granted an exemptive order permitting ICE Clear Europe to commingle customer positions in index CDS and single-name CDS carried through FCM/BD Clearing Members in a single account;” Please follow general accepted accounting procedures. Commingling customer positions do not seem to be in the best interest of the customers. Are they aware that this is occurring? Is this an industry standard?
ATTORNEY AT LAW