The Clearing House Association joined a joint-trades comment letter to the CFTC and SEC on the aggregation of ownership limits for DCOs, DCMs, and SEFs. The letter was filed in response to the position the Department of Justice took in a December 28 letter to the CFTC advocating for stricter aggregation rules for DCOs and expanding similar limits to DCMs and SEFs. The Associations wrote that the DOJ letter does not appear to take into account the regulatory framework established under Dodd-Frank to address the very concerns it cites.