MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules

November 04, 2011

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Topics: Commodity Futures Trading Commission CFTC, swaps, swap transaction, swap transaction compliance, clearing, trade execution, margining, margining requirements, Dodd-Frank Act, mandatory clearing, Rulemaking, Gary Gensler, central clearing, market participants, buy-side participants, end-user exemptions, product definition rules, Securities and Exchange Commission, SEC, security-based swaps, swap dealer, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, collateral, full-scale clearing, uncleared swaps, liquidity, execution, Category 2 Entities, Category 1 Entities, active fund, buy-side market participants, private funds, swap execution facilities, SEF, Designated Contracts Markets, DCMs, real-time reporting, swap data, Regulators, derivatives clearing organization, futures commission merchants, FCM, non-dealer market participants, clearing mandate, G20, OTC derivatives, over-the-counter derivatives, exchanges, electronic platform, central counterparties, CCP, federal register, class of swaps, voluntary clearing, Category 3 Entities, Scott O'Malia, compliance schedules, compliance date, made available for trading, partial tear-ups, novations, third-party subaccount, non-MSP counterparties, interest rate swaps, broad-based index credit default swaps, commodity swaps, systemic risk, real-time clearing, cost-benefit analysis, price distortion, bilateral execution, execution venue, listing, security-based swap SEF, Category 4 Entities, trading documentation, phased implementation, transparency, prudential regulators, variation margin, netting, counterparties,
From: MFA, Stuart Kaswell

To:

David Stawick, CFTC
Gary Gensler, Bart Chilton, Jill Sommers, Scott O'Malia, Mark Wetjen, CFTC

The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets once the pending rules are adopted – affecting all OTC market participants.  MFA’s comment letter provided constructive recommendations to the CFTC in implementing final rules on clearing, trade execution, trading documentation and uncleared swap margining requirements in a way that will achieve mandatory clearing in a timely manner in U.S. markets, while avoiding disruption or undue strain on the resources of market participants and regulators.  MFA’s comments to the CFTC supported the CFTC’s phased implementation approach to mandatory clearing, as determined by the category of market participant.

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