Commissioner Sharon Bowen of the Commodity Futures Trading Commission again called for finalizing rules on the governance of US designated contract markets, swap execution facilities and derivatives clearing organizations proposed by the CFTC in October 2010. (Click here to see Ms. Bowen’s prior comments on this subject in the article “CFTC Commissioner Bowen Says It’s Time to Consider DCO, DCM and SEF Governance” in the May 10, 2015 edition of Bridging the Week.) Among other things, Ms. Bowen advocated not only having qualitative standards regarding the number of board directors that must be public directors (e.g., the lesser of at least 35 percent or two persons), “but a holistic review of the board’s independence at regular intervals.” Ms. Bowen also suggested that governance rules for DCMs, SEFs and DCOs in the United States might borrow from regulations governing clearinghouses under the European Markets Infrastructure Regulation. Specifically, Ms. Bowen claimed that EMIR’s requirement that a clearinghouse “have robust governance arrangements, which include a clear organizational structure with well-defined, transparent and consistent lines of responsibility, effective processes to identify, manage, monitor and report the risks to which it is or might be exposed, and adequate internal control mechanisms, including sound administrative and accounting procedures” could be generally adopted by the CFTC for DCMs, SEFs and DCOs. Commissioner Bowen issued her views before the Quadrilateral Meeting of the European Central Bank on June 24, 2015.