JordanandJordan comment letter on tri partyrepo reform

June 7, 2010 Federal Reserve Bank of New York 33 Liberty Street New York, New York 10045 Re: Request for Comments – Tri-party Repo Infrastructure Reforms Jordan & Jordan appreciates the opportunity to respond to the white paper published by The Federal Reserve Bank of New York (“FRBNY” or “The Bank”) on May 17, 2010 discussing Tri-Party Repo Infrastructure Reform. Jordan & Jordan would like to commend the Bank’s Payments Risk Committee on its actions in forming the Tri-Party Repo Infrastructure Reform Task Force to address the many concerns presented by the critical tri-party financing function. We would also like to congratulate the Task Force for their significant effort in preparing their report and recommendations to date, although there remains much work to be done. Jordan & Jordan is a professional services firm that provides business and technology solutions to the financial services industry. Having been engaged in past years by The Bond Market Association (now SIFMA) as project manager and subject matter experts to implement the recommendations made by the Fed-sponsored private-sector Working Group on NewBank Implementation, we have had extensive dealings with many key players in the tri-party markets, and developed a firm grasp of many of the issues. We believe that the insights we gained on the NewBank project give us a unique perspective on this important market and we have been looking forward to the publication of ...