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lobbying and transparency August 17, 2009

Posted by Bradley in : lobbying , trackback

Bodies which seek comments on regulatory proposals don’t always make public the comments they receive, and they are not necessarily consistent in how they deal with comments. Comments are sometimes published by the recipients, sometimes not. Similarly, trade associations which make comments sometimes publish the full text and sometimes do not. For example, I have noted in the past that ISDA makes public only some of its comment letters. But that doesn’t explain why a joint submission to the EU Commission on European financial supervision by SIFMA, LIBA and ISDA should be made public by LIBA, but presented by SIFMA Europe as being only available to its members. And, as of today, the comment letter doesn’t even appear in ISDA’s list of comment letters.

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