Michael Greenberger, Closing Wall Street's Commodity and Swaps
Betting Parlors: Legal Remedies to Combat Needlessly Gambling Up
the Price of Crude Oil Beyond What Market Fundamentals Dictate
(September 10, 2012), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, George Waddington, Law and Policy Analyst, Center for
Health and Homeland Security and Public Citizen's Congress Watch,
to Chairman Spencer Bachus, Financial Services Committee, Request
for Public Input on Volcker Rule Alternative, (September 7th, 2012),
available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, George Waddington, Law and Policy Analyst, Center for
Health and Homeland Security and Public Citizen's Congress Watch,
to David A. Stawick, Secretary, Commodity Futures Trading
Commission, Proposed Guidance on Cross-Border Application of
Certain Swaps Provisions of the Commodity Exchange Act (August 27,
2012), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, George Waddington, Law and Policy Analyst, Center for
Health and Homeland Security and Public Citizen's Congress Watch,
to David A. Stawick, Secretary, Commodity Futures Trading
Commission, Exemptive Order Regarding Compliance with Certain
Swap Regulations (August 13, 2012), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, Jung Lee, Law and Policy Analyst, Center for Health and
Homeland Security and Americans for Financial Reform, to John
Walsh, Acting Comptroller, Office of the Comptroller of the Currency,
Robert E. Feldman, Executive Secretary Federal Deposit Insurance
Corporation, Jennifer J. Johnson, Secretary, Board of Governors of the
Federal Reserve System, Alfred M. Pollard, General Counsel, Federal
Housing Finance Agency, and Gary K. Van Meter, Acting Director, Office
of Regulatory Policy, Farm Credit Administration, Margin and Capital
Requirements for Covered Swap Entities (July 11, 2011), available
here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, Jung Lee, Law and Policy Analyst, Center for Health and
Homeland Security and Americans for Financial Reform, to David A.
Stawick, Secretary, Commodity Futures Trading Commission, Capital
Requirements of Swap Dealers and Major Swap Participants and
Margin Requirements for Uncleared Swaps for Swap Dealers and
Major Swap Participants (July 11, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, and Americans for Financial Reform, to Mary J. Miller,
Assistant Secretary for Financial Markets, Office of Financial
Institutions Policy, Department of the Treasury, Determination of
Foreign Exchange Swaps and Forwards under the Commodity
Exchange Act (June 6, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Swap Trading Relationship Documentation
Requirements for Swap Dealers and Major Swap Participants (April 9,
2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Commodity Options and Agricultural Swaps (April 4,
2011), available here.
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Michael Greenberger, Will the CFTC Defy Congress's Mandate to Stop
Excessive Speculation in Commodity Markets and Aid and Abet
Hyperinflation in World Food and Energy Prices: Analysis of the
CFTC's Proposed Rules on Speculative Position Limits (April, 2011),
available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Position Limits for Derivatives (March 28, 2011),
available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Risk Management Requirements for Derivatives
Clearing Organizations (March 22, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to Elizabeth Murphy, Secretary, Securities and Exchange
Commission, and David Stawick, Secretary, Commodity Futures
Trading Commission, Further Definition of “Swap Dealer,” “Security-
Based Swap Dealer,” “Major Swap Participant,” “Major Security-Based
Swap Participant,” and “Eligible Contract Participant” (February 22,
2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, End-User Exception to Mandatory Clearing of Swaps,
RIN 3038-AD10 (February 22, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, and Americans for Financial Reform, to David Stawick,
Secretary, Commodity Futures Trading Commission, CFTC RIN 3038–
AC20; Swap Data Repositories (February 22, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, Barbara Roper, Director of Investor Protection, Consumer
Federation of America, Lisa Donner, Executive Director, Americans for
Financial Reform, and Damon Silvers, Director of Policy and Special
Counsel, AFL-CIO, to David Stawick, Secretary, Commodity Futures
Trading Commission, Business Conduct Standards For Swap Dealers
and Major Swap Participants With Counterparties, RIN number 3038—
AD25 (February 22, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Implementation of Conflicts of Interest Policies and
Procedures by Swap Dealers and Major Swap Participants (January
24, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Regulations Establishing and Governing the Duties of
Swap Dealers and Major Swap Participants (January 24, 2011),
available here.
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Derivatives in the Crisis and Financial Reform, in THE POLITICAL
ECONOMY OF FINANCIAL CRISES, Oxford University Handbook
(Gerald Epstein & Martin Wolfson eds., forthcoming, 2011), available
here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Process for Review of Swaps for Mandatory Clearing
(January 3, 2011), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Prohibition of Market Manipulation (January 3, 2011),
available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, ICE Trust U.S. LLC – Application for Registration as a
Derivatives Clearing Organization Pursuant to Section 5b of the
Commodity Exchange Act and Part 39 of the Regulations of the
Commission (December 17, 2010), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Notice of Proposed Rulemaking on Financial Resources
Requirements for Derivatives Clearing Organization (December 13,
2010), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to Mary J. Miller, Assistant Secretary for Financial Markets,
Office of Financial Institutions Policy, Department of the Treasury,
Determination of Foreign Exchange Swaps and Forwards (November
29, 2010), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Notice of Proposed Rulemaking on Agricultural
Commodity Definition (November 26, 2010), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Requirements for Derivatives Clearing Organizations,
Designated Contract Markets, and Swap Execution Facilities
Regarding the Mitigation of Conflicts of Interest (November 17, 2010),
available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to Timothy Geithner, Secretary, Department of the Treasury,
Chairman, Financial Stability Oversight Council, Public Input for the
Study Regarding the Implementation of the Prohibitions on Proprietary
Trading and Certain Relationships with Hedge Funds and Private
Equity Funds (November 5, 2010), available here.
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Comment Letter by Michael Greenberger, Professor, University of
Maryland School of Law, Director, Center for Health and Homeland
Security, to David Stawick, Secretary, Commodity Futures Trading
Commission, Definitions Contained in Title VII of Dodd-Frank Act, File
No. S7-16-1 (September 20, 2010), available here.
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Is Our Economy Safe? A Proposal for Assessing the Success of Swaps
Regulation under the Dodd-Frank Act, in THE FUTURE OF FINANCIAL
REFORM: WILL IT WORK? HOW WILL WE KNOW? (Roosevelt Institute
2010), available here.
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Out of the Black Hole: Reining in the Reckless Market in
Over-the-Counter Derivatives, AMERICAN PROSPECT (2010),
available here.
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Out of the Black Hole: Regulatory Reform of the Over-the-Counter
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