On November 21, MFA submitted a comment letter to the CFTC in response to the MAT submissions of Javelin SEF, LLC; trueEX, LLC; and TW SEF LLC for certain interest rate swap products. MFA’s letter proposes that the CFTC phase in the trade execution requirement on registered swap execution facilities (SEFs) and designated contract markets (DCMs) by product and transaction type for the rates asset class, beginning with outright, spot-starting, USD and EUR swaps at the benchmark tenors in the fixed-to-floating interest rate swap class. This initial phase would be followed by progressive phased expansion of the trading mandate to include additional currencies, tenors, and forward start dates in the fixed-to-floating swap class, as well as to other swap classes. MFA’s letter also recommends a similar phase in to cover “package transactions” (as opposed to outright swaps). The letter compares MFA’s recommendations to the Javelin SEF, trueEX and TW SEF MAT determinations. MFA’s letter also raises certain operational readiness issues for SEF/DCM trading that the CFTC should address in connection with the phase-in of the trading mandate.