Comment Letter on Proposed Rule and Interpretation on Registration and Regulation of Security Based Swap Execution Facilities

April 04, 2011

From: MFA, Stuart Kaswell

To:

Elizabeth Murphy, SEC
Mary Schapiro, SEC.
Kathleen Casey, Elisse Walter, Luis Aguilar, Troy Paredes, (all) SEC.

MFA submitted a comment letter to the SEC on its proposed rule and proposed interpretation on Registration and Regulation of Security-Based Swap Execution Facilities. In our letter, MFA: (i) supported SEC-approved objective, transparent criteria to determine when an security-based swap execution facility (SB SEF) can make a security-based swap available to trade; (ii) supported a request for quote (RFQ) model that permits a quote-requester to send an RFQ to a single liquidity provider or recipient; (iii) encouraged the SEC to permit the execution of block trades in one participant to one participant transactions that could then be printed on an SB SEF; and (iv) articulated concern for the discretion afforded to an SB SEF to preclude access to its platform to any eligible contract participant that is not registered with the SEC as a security-based swap dealer, major security-based swap participant or broker.

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