Comment Letter to the CFTC on Real-time Public Reporting of Swap Transaction Data and Swap Data Recordkeeping and Reporting Requirements

MFA submitted a combined comment letter to the CFTC on Real-time Public Reporting of Swap Transaction Data and Swap Data Recordkeeping and Reporting Requirements. In our letter, MFA expressed concerns about the confidentiality of swap transaction data and asked the CFTC to verify which data is subject to the public dissemination requirement. We also expressed concern about the CFTCs tests for determining minimum block sizes, and we strongly encouraged the CFTC to first conduct a study to identify proper minimum block levels that will not harm the swap markets. We also made comments related to non-standardized trades, timing of reporting, dispute resolution and phasing in the requirements.

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