Comment Letter to the CFTC on Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants

MFA submitted a comment letter to the CFTC on Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants. In our letter, MFA recommended that the CFTC make careful and appropriate distinctions between the requirements for swap dealers (SDs) and those for major swap participants (MSPs) to reflect the fundamental differences in their businesses, structures and characteristics. In particular, we respectfully requested that the CFTC make certain changes to the proposed rule so that MSPs are not generally required to maintain certain records and information that are only appropriate for, and customarily maintained by, SDs because of their market making activities. We provided a specific enumerated list of the reporting requirements in the proposed rule to which we thought this request should apply.

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