The Clearing House Association filed a comment letter to address the CFTC’s proposed exemptive order regarding delayed compliance with certain swap regulations. In the letter, TCH urges the CFTC to revise the proposed order to: (i) provide a complete exemption from the application of rules or concepts that are still subject to comment or significant ambiguities, (ii) treat swap dealers equally and consistently so that the relief itself does not create an unlevel playing field among market participants, and (iii) incorporate a sufficient amount of time to accomplish its purpose of providing an orderly transition to the new regulatory regime as well as to changes in non-U.S. regulatory regimes.