MFA Submits Joint Letter Requesting Extension of CFTC Cross-Border Comment Deadlines

July 16, 2012

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On July 16, MFA and nine other trade associations submitted a joint comment letter to the Commodity Futures Trading Commission (“CFTC”) in response to its proposed interpretive guidance as to the cross-border impact of Title VII (the “Proposed Guidance”) and proposed exemptive order that would temporarily exempt market participants from Title VII requirements subject to certain conditions (the “Proposed Order”).  Because the Proposed Guidance and Proposed Order will have a significant impact on how the global derivatives markets will be regulated and will have broad repercussions on how each association’s members conduct their swaps business, in that letter, we requested that the CFTC extend the period for public comments on the Proposed Guidance and Proposed Order to 60 days, which would make comments due on each no later than September 10, 2012.  Currently, comments on the Proposed Guidance are due no later than August 27, 2012 (i.e., 45 days after publication in the Federal Register), and comments on the Proposed Order are due no later than August 13, 2012 (i.e., 30 days after publication in the Federal Register).

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