As a follow up to public comment R-1629-133537 "Calculating Exposure Amount of Derivative Contracts," dated for March 14, 2019 for public comment period due March 18, 2019, a revisitation of the context is appropriate.
One means by which to evaluate scenarios involving the use of derivative agreements and the exposure that can occur and that should be considered to be acceptable can be considered in regards to standards applied in transportation and distribution systems. The impact on "pooling" or "aggregation" of value should be evaluated not just as if within a risk-centered variegation. An array system of distinguishing value streams that can be consistently maintained to implement appropriate firewalls for cybersecurity functions can and should be established in accordance with appropriate and comprehensive, necessary disclosures on access to and by national security and law enforcement functions so as to appropriately factor in risk.
A reconceptualization of concepts of leveraging in accordance with a more distinct classification paradigm can counter-balance, as opposed to "offset," the strategy recommended concerning access to and use of Tier I Capital per public comment period for "Risk Based Capital Requirements for Companies Significantly Engaged in Insurance Activities" announced in the Fall of 2019. It is worth noting that on Oct. 29, 1979 there was a memorandum provided by the Comptroller General of the United States Elmer B. Staats regarding the development of database systems for the government that were meant to provide different access levels and aggregation features for data involving federal databases that was intended to be made accessible to people across departments. An analysis of distribution risks needs to include evaluations of risk factors concerning smuggling potentials without appropriate distinction and adherence to complaince standards throughout the streaming process.
9:17 am CST
March 14, 2020
Proofread and posted by 9:35 am CST
Comments