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Concurring Statement Of CFTC Commissioner Sharon Y. Bowen Regarding Cross-Border Margin Rule, May 25, 2016, Margin And Capital As The Pillars Of Market Safety

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Margin and capital are two of the most important tools for risk mitigation for the derivatives markets. Thus it is very important that we get our rules on margin and capital right in order to accomplish the reform required under the Dodd-Frank Wall Street Reform and Consumer Protection Act.1 As many of you know, last December, I voted against the final margin for uncleared swaps rule because I did not believe that it was strong enough to fully protect our system. As I said in December, adequate margin is fundamental to market safety as it is a “critical shock absorber for the bumps and potholes of our financial markets and for the risk of contagion and spillovers.”2 I am even more confident in that view today.

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