Comment Letter Responding to CFTC and SEC on a Study of the Feasibility of Requiring the Derivatives Industry to Adopt Standardized Computer-Readable Algorithmic Descriptions

MFA submitted comments to the CFTC in response to the CFTC and SECs request for comments on a study mandated by Dodd-Frank on the feasibility of requiring the derivatives industry to adopt standardized computer-readable algorithmic descriptions which may be used to describe complex and standardized financial derivatives. MFA members support and continually work to standardize industry practices and terms, where appropriate. In our letter, however, we explain that the use of standardized computer readable algorithmic descriptions is only possible where the terms of the derivatives are sufficiently uniform.