Barry L.

Zubrow
Executive Vice president
Chief Risk Officer

Mr. David A. Stawick Ms. Elizabeth M. Mur phy

Secretary Secretary
Commodity Futures Securities and Exchange
Trading Commission Commission
'l00 F Street, N. E.
Three Lafayette Centre
1155 21"Street„N.W. Washington, D.G. 29549-1090
Washington, D. C. 20581

November 17, 2010

and Swap
Re: Requirements for Derivatives Clearing Organizations, Designated Contract lNarkets,
interest - 75 Fed. Reg. 63732 (October
Execution Facilllties Regarding 'the Mitigation of Conflicts of
18, 2010);
for Derivatives Clearing Organizations - 75 Fed. Reg. 63113
Financial Resources Requirements
(October 14, 2010); and
Clearing
Ownership Limitations and Governance Requirements for Security-Based Swap
National Securities Exchanges with
Agencies„Security-Based Swap Execution Facilities, and (October 26, 2010).
Regulation MC -76 Fed. Reg. 66882
Respect to Security-Based Swaps Under
Futures Trading Commission
VVe welcomethe opportunity to provide comments to the Commodity
Commission ("SEC") ((each "the Comfnission" and together
("CFTC") and the Securities and Exchange
to requirements applicable to (a) Designated Contract Markets and
the "Commissions") with respect
National Securities Exchanges (referred to in this letter as
"exchanges"); (b) Swap Execution Facilities
"SEFs" in this letter); and (c) Derivatives
and Security Based Swap Execution Facilities (referred to as
Agencies (referred to as "clearing houses" in
Clearing Organizations and Security Based Swap Clearing
this letter),
have been clearing dealer to dealer
J.P,Morgan is committed to clearing OTC transactions and in fact we
made significant investments in our client clearing franchise and
OTC transactions for a decade, VVe have
service.
we employ several hundred people in support of our client clearing

aimed at mitigating conflicts of interest. We also support full

Nfe strongly support regulation
Wall Street Reform and
implementation of the open access core principles set out by Congress in the
not of the final text of the Act
Consumer Protection Act, VVe note that the Lynch amendment was part
Sections 724 and 726 of the Wall Street Reform and
passed by Congress and signed by the President. final regulations
Commissions to conduct a review prior to issuing
Consumer Protection Act require the
submit that it would be appropriate to conduct
regarding the matter of conflict of interest. We respectfully believe that
the rulemaking activity. VVe
further review with respect to the subject matter prior to finalizing
analysis of vvhether the imposition of the limits, as they are
an important part of the review would be the 1
conflicts of interests,
currently being proposed would be required or beneficial to mitigate
to whoever meets certain minimum
We believe that all clearing houses should provide open access
house relies almost exclusively on the capital of its
objective criteria, In our view the fact that a clearing

ability of clients to chose whether accessing a dealer

' It wouldbe very useful to have a better sense of whether a curtailment of the
vendor platform would increase competition or merely increase end user cost. In other markets
owned platform or a third party
between dealer direct access platforms and intermediaries, clients often chose deafer
where clients have the option of choosing
direct platforms.

270 Park Avenue, New York, New York IOOD

Telephone 212 2/0 0593 Facsimile 2I2 270 7320 barry. l, zul&row@lpmchase. corn

JPMorgan Chase 5 Co.

 losses resuiting
members places a great emphasis on the ability of a member to absorb any
introduces into the clearing house;
from: (a) the house and client risk that that clearing member
and (b) mutualization of the risks introduced by every other
clearing member and that clearing
believe that the
member's clients. Given the loss mutualization feature of clearing houses, we
that must be satisfied for a
financial stability of clearing houses depends on the requirements
defined, should require
member to qualify as a clearing member. Those criteria, however
it is our view that the way to
clearing members to hold a minimum amount of capital. In addition of
the safety and soundness
provide open access to new clearing members while promoting
to clear house and client
clearing houses wouid be to provide clearing members with the ability
the amount of capital available to them as well as to funded margin and
risk in proportion to
guarantee fund contributions. We do not support any exclusionary practices.

clearing houses. In
We support regulations requiring the creation of a risk committee at all
for the separation of the
addition, we believe it would be appropriate for regulations to provide
management function (Risk
corporate governance function (Board of Directors) from the risk
Committee) within a clearing house.

Risk Corrtfytittee
of clearing member
We believe that the risk committee should be comprised of a majority
participation. We support a requirement to for
representatives, with the remainder open to client
of client representatives with relevant
at least IO per cent of the risk committee to be composed
independent representatives. VVe
expertise, and the remainder to be open to participation by guarantee
should be the preservation of the
believe that the main focus of the risk committee
fund that is utilized to safeguard the clearing house and its
members against defaults, taking
standards, including mitigation of systemic risk. The
into account prudent risk management
main focus of the Board would be to promote the commercial interests of the clearing house.
and the board would be able to achieve a
VVe expect that in most cases the risk committee
requirement for the Board to
productive balance between those two interests. VVe support a
the risk committee
consult with the appropriate regulator prior to rejecting a recommendation by
to risk would fall within the purview of the risk
on matters of risk. In our view all matters relating
of the guarantee
committee. This would include all matters related to margin and the sizing
application, and the enumeration of products eligible
fund; membership criteria and membership
for clearing. The CFTC identified sound risk management standards
as well as open access as
key factors that must be addressed in determining whether
a particular type of swap is suitable
for clearing'.

of Swaps for Mandatory Clearing, 75 Fed, Reg. 67277

please refer to CFTC draft regulations regarding the process for Review
the swap, or group, category, type, or class of swaps that
(November 2, 2010). The draft regulations refer to "information regarding
sufficient to provide the Commission a reasonable basis to make a quantitative and qualitative assessment of the following
is
liquidity, and adequate pricing data; (Et) The
factors: (A) The existence of significant outstanding notional exposures, trading
operational expertise and resources, and credit support infrastructure to clear the contract on
availability of rule framework, capacity,
terms and trading conventions on which the contract is then traded; (C) The effect on the
terms that are consistent with the material
size of the market for such contract and the resources of the DCO available to
mitigation of systemic risk, taking into account the
applied to clearing, and (E) The existence
'
fees and charges
clear the contract; (D) The effect on competition, including appropriate one or more of Its clearing members with regard
relevant DCO or
of reasonable legal certainty in the event of the insolvency of the of
customer and swap counterparty positions, funds, and property; (iii) Product specifications, including copies
to the treatment of
generally accepted contract terms, standard practices for managing any life cycle events
any standardized legal documentation,
confirmable; (iv) Participant eligibility standards, if
associated with theswap, and the extent to which the swap is electronically
general participant eligibility standards; (v) Pricing sources, models, and
different from the derivatives clearing organization's
data to measure credit exposures in a timely and accurate manner,
procedures, demonstrating an ability to obtain sufficient price
agreements with clearing members to provide price data and copies of executed agreements with third-party price
including any the
such as the name of the index, the source that calculates it,
vendors, and information about any price reference index used,
Board of Directtors

With respect to the corporate governance function of SEFs, exchanges and clearing houses, we
support encouraging a balance of views being represented on
the Board of Directors. N/e think
that a 35% requirement for independent directors will be problematic to implement in practice
of individuals who are not already
because it will be difficult to identify a sufficient number
involved in the industry and who have appropriate level of practical market experience. In our
be achieved identifying different
view the desired balance between different interests can by
representation of those interests in the
classes of interested parties and encouraging a diverse
that no single class of interested parties
Board of Directors, This would be done by requiring
house
achieves more than a 65% of the seats on the board. Each SEF, exchange and clearing
of the seats, The Commissions would
should be able to determine how to fill the remainder
provision. our opinion the different
monitor compliance with the letter and the spirit of this In

classes of interest parties vary depending on the type of entity:

whose capital is at
In the case of Clearing Houses the classes would be: (a) clearing members
end users, who have an interest in
risk if another clearing member or one of its clients fail; (b)
costs low; and (c) other investors and
protecting their collateral and in keeping clearing
infrastructure providers (e.g, technology providers, SEFs, exchanges and clearing houses), who
have an interest in increasing profitability.
takers; and (c)
In the case of SEFs the classes would be: (a) liquidity providers; (b) liquidity
technology providers, exchanges and clearing
other investors and infrastructure providers (e.g,
houses), who have an interest in increasing profitability.

takers; and (c)

In the case of exchanges the classes would be: (a) liquidity providers; (b) liquidity
other investors and infrastructure providers (e. g. technology providers, SEFs and clearing
houses), who have an interest in increasing profitability.

would have the added benefit of promoting competition and discouraging

These limitations
vertical integration of exchanges, SEFs and clearing houses.

significant independent representation on the Regulatory Oversight

)/Ve support having
note that some clearing member and client representation on the
Committee, and we
Committee would be appropriate. Both these categories of clearing users
Regulatory Oversight
have a vested interest to ensure compliance with all appropriate regulations.

is calculated, and when and where it is published publicly,

methodology used to calculate the price reference index and how often it
measurement and monitoring of credit exposures, initial and variation margin
(vi) Risk management procedures, including
and back testing, settlement procedures, default management procedures, and an
methodoiogy, methodologies for stress testing
clearing organization's risk management policies, systems, and
independent validation of the scalability of the derivatives
default management procedures; (vii) Measures of
procedures, including the margin methodology, settlement procedures, and
market liquidity and trading activity, including information on the sources
of such measures; (viii) An analysis of the effect of a
clearing requirement on the market for the group, category, type, or class of swaps, both domestically and globally, including the
trading activity, use of swaps by direct and indirect market participants, and any potential market
potential effect on market liquidity,
policies, or procedures; (x) Terms and trading conventions on which the swap is currently
disruption; (ix) Applicable rules, manuals,
traded; (xi) A description of the manner in which the derivatives clearing organization has provided notice of the submission to its
"
the members.
members and a summary of any opposition to the submission expressed by
 clearing houses should have the
To avoid duplication, we believe that exchanges, SEFs and
option to choose, in coordination with their regulators,
whether they will implement a structure
on a Reguiatory Oversight Committee, but
relying on a Chief Compliance Officer or one relying
we do not recommend requiring both.
operations of the
All those who bring risk into the clearing house or profit from the
cilearing house should have "skin in the game"
whose
VVe think it is essential to the development of a sound clearing infrastructure that those
houses. Clearing houses rely
capital is at risk can participate in the risk management of clearing
of clearing members to
almost exclusively on the margin and guarantee fund contribution
model, shareholders in a
manage systemic risk and counterparty risk, ln a verticaliy integrated
in the future may also own SEFs)
holding company that owns clearing houses, exchanges (and
are exposed to a fraction of the risk that clearing members are exposed to through loss
mutualization, There is no current requirement for clearing houses to provide
a first loss piece to
house "skin in the game"
the financial waterfall package and in most structures the clearing
fund, For this reason the
contribution is minimal compared with the overall size of the guarantee
of the margin and guarantee
large majority of the capital at risk of a clearing house is composed to satisfy
financial resources required
fund contributed by clearing members, ln addition to the
Street Reform and Consumer
the financial safeguards core principles set out in the Wall
Protection Act' we support introducing a requirement for clearing houses to carry a first loss risk
In our view this would incentivize ciearing
component in the waterfall of financial safeguards. limits on the ability of
houses to manage risk in a prudent manner. Nfe would also support
fees to their holding companies
clearing houses to upstream dividends resulting from clearing
and the introduction on
when a clearing member defaults. The introduction of a first loss position benefits
of dividends for clearing houses would result in significant
limits on the upstreaming
from a systemic stability point of view.

requirement is to
The best way to promote a successful implementation of the clearing trading
risk a prudent manner, while
ensure that clearing houses are fuily equipped to manage in
order to achieve this purpose,
providing open access to clients and clearing members. In
intellectual capital from those who have
clearing houses should be able to attract financial and
intends to clear, as well as from new
experience in the products that the clearing house at
derivatives market is sufficiently diversified
participants into the market. We note that the OTC
October 25, 2030' shows that the five
present. A market survey published by lSDA on Monday,
derivatives market (equity, rates,
largest US-Based dealers hold 37 percent of the outstanding
of the giobal nature of the OTC derivatives
credit), In our view this data is more representative
market than other data' that has been quoted out of contest in the debate regarding conf'lief. of
US institutions and was
interest. That data was focused exclusively on a restricted number of
market, which is globai by virtue of buy side, sell
not intended to represent a survey of the OTC
that dealers would acquire shareholdings in
side, regulators and execution venues, To assume
over a clearing house with a view to impede or
a clearing house or otherwise gain influence of
narrow the implementation of the clearing requirement would be inconsistent with the reality
have made significant
today's markets, On the contrary some participants in the OTC markets

' Also see draft CFTC g 39.11, 76 Fed. Re9. 63118

' (IDDA Mio Y ar ktlt0 Markat svrvay, availaola on ~~lsDA
or
 advance of a legal requirement to clear
investments into the capital of clearing houses well in

being introduced or proposed in the US or in Europe.

At this point in the deveiopment of market infrastructure it is essential to promote competition

houses, we note that
between clearing houses, exchanges and SEFs. With respect to clearing
houses per asset class that are able
in today's markets there are a maximum of three clearing
house currently clearing.
to clear QTC derivatives, ln some asset classes there is no clearing
the expertise and the funds to
There is no specific reason to apply limits only to those who have
management of the clearing
finance a clearing house and who are exposed to losses if the risk
at risk from acquiring the right to
house fails. We believe that preventing those whose capital is
role the OTC markets is not
vote on the governance of the entities that perform a key in
the Wall Street Reform and
necessary to achieve the poiicy objectives set out by Congress in
to
rights that would apply
Consumer Protection Act, For this reason we support a limit on voting
are clearing members, SEFs,
each class of market participants irrespective of whether they
would promote open
exchanges, enumerated entities, other types of entities or individuals, This
access and greater competition among clearing houses,
10'/o cap on voting rights for each
In addition, rather than the proposed 5% we would support a
entity (irrespective of whether they are clearing members, SEFs, Exchanges, enumerated
or individuals} with no limit on the voting
entities, holding companies, other types of entities
rights that any one class of investors can hold.
should apply to shares that
The Commissions solicited views on whether ownership limitations
do not carry voting rights. Given that preference shares and other types of non voting shares
house and have no effect on corporate
are a way to provide liquidity into the clearing
to limitations on the ownership of
governance, we believe that it would not be appropriate apply
non voting shares.

- Financial Resources Requirements for Derivatives Clearing

Risk management
Organizations
one portion of a clearing
We note that it is not appropriate to make determinations regarding any
assessed in the context
house risk management framework in isolation, since each portion must be framework of
the management
of how such portion interacts with the remaining components of
risk
classes to be cleared under that framework,
that clearing house and the particular asset class or
of the risk management framework of a clearing
Making determinations with respect to one portion
leave the overall structure incomplete with the resulting
house in isolation has the potential to
we appreciate this opportunity to offer our initial comments
systemic risk, For this reason,
Clearing Organizations. We are
regarding Financial Resources Requirements for Derivatives
that the same reasoning
sharing these comments with both CFTC and SEC as we believe
SEC regulated security based swaps,
applies to CFTC regulated swaps as it applies to

agree with the underlying premise enunciated in the proposed CFTC

$39.11,
We strongly
sufficient resources to cover its
namely that a derivatives clearing organization must maintain
functions in compliance
exposures with a high degree of confidence and to enable to perform its
section 5b(c) of the Commodity Exchange Act, as amended by
with the core principles set out in
the Wall Street Reform and Consumer Protection Act.
the tools to manage that risk in
We believe it is essential that clearing houses are equipped with
a safe and sound manner, This requirement is particularly acute
as we prepare to transfer the
clearing houses rather than
risk for the majority of the OTC markets through interconnected
 market structure is that the ability of a
through bilateral agreements, The effect of this change in
counterparty basis
market participant to manage their counterparty risk on a counterparty by
to mutualize losses in support of
has been replaced with the that market participant's obligation are clearing
Market participants who
the clearing house and of other clearing members.
other clearing members as well as being
members will be exposed to the risk of default by
other clearing members. Unless clearing
exposed to a risk of default by the clients of those default
would also be exposed to a risk of
houses are deemed too big to fail, market participants
by clearing houses themselves.

where some
We do not believe that there should be a two tiered approach to membership,
mutualization and others are not. A clearing house will rely
clearing members are subject to loss
on the financial resources waterfall set out in CFTC proposed $39. 11. This includes funded
member. CFTC proposed $39, 11 also contemplates
guarantee fund contributions by a clearing
for additional default fund
the ability of a clearing organization to assess a clearing member
to make sure that a clearing member will have
contributions. We believe that it is important
in proportion to house
sufficient liquid capitai to fund additional guarantee fund assessments,
and client business cleared by that clearing member.
have the ability to provide
We believe it would be appropriate to require that clearing members
for all points in the curve for all products cleared. Clearing
daily executable binding quotation
Clearing members
Houses must be able to mark risk to market at the end of each trading day,
than reiying on whether the
must provide daily prices for all points of the maturity curve rather
cleared product trades on an exchange or a SEF on that day.
have the operational ability
In our view it would be appropriate to require that clearing members
including porting books
to sustain the flow ot client and house positions into the clearing house,
party pricing and
of liquid and illiquid positions at times of market distress, We think
third
For this reason we
outsourced default management services can disappear quickly in a crisis,
able to participate in the
recommend a requirement that clearing members or their affiliates be
default management process.

the value of unfunded

We support the CFTC proposal requiring clearing houses to haircut
can be met by
assessment and to cap the percentage of the financial resources package that
the value of assessments.
contribution of a clearing
We note that CFTC proposed $39.11 also refers to the own capital
We believe that it would be
house as a component of the financial resources package.
and require that if a
appropriate for the Commission's Regulations to provide greater
granularity
waterfall, that clearing house must
clearing house enumerates its own capital as part of the and
available to meet those obligations
provide sufficient assurances that its the capital will be
discretion of that clearing house.
will not be reallocated to serve other purposes at the

should be noted that a clearing member may have committed

to additional assessments at
lt
be appropriate for Regulators to adopt a risk
more than one clearing house. We believe it wouid
member will be able to meet its
based analysis to determine the likelihood that a clearing
assessment obligations across all clearing houses.
 house has adequate liquidity in a
We share the view that it is crucial to ensure that a clearing
house must hold: (i)
crisis. We understand the proposed $39, 11(e) to mean that a clearing
financial resources that are sufficiently liquid to meet its obligations as
a central counterparty
and sufficient capital in the form of cash to meet the
during a one day settlement cycle, (ii)
average daily variation pay per clearing member over the iast fiscal quarter.
of the financial
We note that $39, 11(e)(1} also provides that if any portion of the remainder
into account a
resources is not sufficiently liquid, the derivatives clearing organization may take
requirement.
committed line of credit or similar facility for the purpose of meeting this

VVe understand $39, 11(e) to mean that a clearing house must hold sufficient
cash and/or highly
costs, and that if any of those resources
liquid securities to meet at least six months' operating
of credit or similar facility
are not liquid, a clearing house may take into account a committed line
for the purpose of meeting this requirement.
or similar liquidity facility, it
In our view if a clearing house has in place a committed line of credit
amount of risk into the
would be appropriate for all clearing members who introduce a significant
commitment to be open to non clearing
clearing house to share in that commitment, and for the
members a committed line of
members. It is worth noting that greater participation by clearing in
a component of providing
credit or similar liquidity facility at times of market distress is key
liquidity in the settlement system, with clear benefits
for systemic stability,

Ifa clearing house receives illiquid collateral and uses that collateral under the terms of the
liquidity facility that could affect the ability of members
to
committed line of credit or similar
collateral calls and guarantee fund assessments, For this
access sufficient liquidity to meet
reason we believe it is appropriate to diversify broadly the risk and reward of providing such
liquidity.
that is set out in
VVe would be grateful for a clarification of the commentary to these provisions
commentary states that a committed line of credit
the CFTC Notice of proposed rulemaking, The
or similar facility cannot be used for purposes of the financial safeguards set out in f39, 11(b)(1)
commentary states that a DCQ may only use
or the operating costs set out in f39, 11(b)(2)'. The
to meet the liquidity requirements set forth in
a committed line of credit or similar facility amount
that $39. 11(e}(1) refers to the minimum
proposed $39.1'l(e)91} and f39.11(e}(2).Given
requirements of one day
of cash or liquid assets that a DCO must maintain to meet the
settlement cycle and average dally variation margin and six moths operating costs respectively,
a committed line of credit or similar facility for the
we interpret the Regulations to provide that
purpose of meeting this requirement may be used to meet obligations in excess of that minimum
$39, 11(e)(2) we interpret the regulations
requirement. In addition, given the express language in
the
or similar facility can be used to meet liquidity
to mean that a committed line of credit
costs as well as one years of operating costs, We
requirements related to six months operating
requirements. If our
believe it would be very helpful to have further clarification on these
understanding of he Regulations is correct, our view is that these requirements
are adequate to
Reform and Consumer
meet the financial stability requirements set out in the Wall Street
Protection Act.

This is referred to as 39.8(b)(2) in the Notice. We think this is a typographical error and the text was intended to refer to
39.11(bI(2).
Gross margin

We are in favor of requiring clearing houses to hold margin on a gross basis (each client posting
the net of their aggregate position, each clearing member posting to the clearing house the
gross amount of all clearing house required client collateral) rather than net, This requirement
would apply at a minimum to systemically important clearing houses.

our
We believe that the nevv market structure landscape there should be no too big to fail. In
in
members, clearing houses and clients. Given the
view this principle applies equally to clearing
to have skin in the
loss mutuatization feature of clearing, it is only by requiring each participant
risk into the system have an
game that we can ensure all the parties involved in bringing
is of particular
incentive to act in a manner that is prudent, safe and sound. This principle
deemed systemically important by the Financiai Stability
relevance for those entities that are
Oversight Council pursuant to Title Vill of Dodd Frank.

working groups, We
We welcome the active involvement of our regulators in the CPSS-IOSCO
house should be
believe that as part of the designation of systemic importance, a clearing
required to adhere to CPSS-lOSCO standards. With respect
to emergency powers, the
Recommendations
consultative report "Guidance on the application of the 2004 CPSS-lOSCO
CPSS/lOSCO in May 2010
for Central Counterparties to OTC derivatives CCPs" published by
provides that emergency powers of clearing houses should not be used by a clearing house to
' By way of example, we
change the economic of a transaction that has been cleared already,
important) should be
do not believe a clearing house (whether or not designated as systemically
in order to
able to decide that the recovery on a trade is, by way of example, 90%
exclusively
clearing houses need the
avoid incurring a loss at the clearing house. Systemically important
consuit the Risk Committee, the
ability to take emergency action in a crisis if there is no time to
required to revert
Board of Directors or Regulators. However, we believe that SlDCQs should be
to the Risk Committee, the Board of Directors or Regulators as soon
as possible after such
out in Title Vlli of the
action for ratification, well within the "no later' than 24 hours" deadline set
Wall Street Reform and Consumer Protection Act.

ln between regulators who have authority over clearing houses will be a key
our view, coordination
stability. One significant element will be the ability of regulators
to look
component of systemic
members, exchanges, SEFs and clearing houses for any factors that
across clients, clearing
risks, We think it is appropriate
could increase systemic to monitor the activity of clients, clearing
with a view to identify
members exchanges, SEFs and clearing houses for undue concentration

'Web link: htt://www. is. or / ubl/c ss89. df

should have an economically
In particular please refer to page 32: "In principle, a CCP's use of emergency powers
possible, should maintain the relative mutualization of risk that its
neutral effect on its participants, or, if that is not
expect from the Regulations. Therefore, economic consequences that result from the use of emergency
participants
powers should be mitigated to preserve the economic terms of the affected
trades and the original Regulations to the
and be profit neutral, they shouid mandate or
fullest practical extent. Since CCPs must maintain balanced positions
directly acquired as a result of their decision from the beneficiaries to
otherwise mediate the transfer of any windfall
"
the losers of the decision.
 situations before they
those that pose a systemic risk and take action to de-risk problematic
exert a significant impact on the financial systems.

Conctusion
should be too
We believe that no institution, including clearing members and clearing houses
Street Reform and Consumer Protection Act would
big to fail. The policy objectives of the Wall
stability and ensuring safety and soundness of
be well served by promoting systemic
that these institutions have adequate
exchanges, SEFs and clearing houses, and by requiring
capital to absorb losses and sufficient liquidity to safeguard the system,

Thank you for the opportunity to comment publicly on these important

matters, Please contact
J,P. Morgan should you wish to discuss these matters in greater detail,

Sincerely,
r

--: )
) =~
Barry L. Zubrow
EVP 8 Chief Ri~fficer

CC:
Honorable Gary Gensler, Chairman
Honorable Michael Dunn, Commissioner
Honorable Jill E. Sommers, Commissioner
Honorable Bart Chilton, Commissioner
Honorable Scott O'Malia, Commissioner

Honorable Mary L, Schapiro, Chairman

Honorable Elisse B. Walter, Commissioner
Honorable Kathleen L. Casey, Commissioner
Honorable Luis A. Aguilar, Commissioner
Honorable Troy A. Paredes, Commissioner