Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities

March 08, 2011

Click to expand relevant topics

Topics: annual review auction-based methods, available for trading, bilateral trading, bilateral trading environment, block size, block trade thresholds, block trades, cash position, CBOE futures exchange, CEA, central limit order variants, CFTC, chief compliance officer, cleared swaps, Commodity Futures Trading Commission, competition, complete audit trail, conflicts of interest, congestion, connectivity, credit default swaps, crossing, daily trading records requirements, data analysis, DCM, dealer-to-customer platforms, debt instrument, Designated Contract Market, discreet contract, electronic platform, emergency procedure, exchanges, exchanges for physical, exchanges for swaps, execution protocol, fixing, flexibility, futures position, grace period, grandfather relief, institutional investors, interstate commerce, ISDA, joint the trade, large notional transaction size threshold, limit order, linked transactions, liquidity, liquidity characteristics, major swap participants, Mandatory Execution Requirement, mandatory minimum required recipients, mandatory objective criteria, mandatory transparent criteria, Manipulation, market efficiencies, market liquidity, market-based competition, matching, matching traders, minimum block sizes, minimum block threshold, multiple-to-multiple trading venues, non-continuous liquidity, off-market transactions, one-to-one voice services, open outcry trading pits, order book, order book systems, OTC, OTC market, Over-the-Counter, Over-the-Counter Derivatives Markets, packaged transactions, permitted transactions, physical contract, physical position, price distortion, public information, quote requesters, quote-requesting participant, real-time public reporting of swap transaction data, recordkeeping requirements, regulatory efficiencies, reporting requirements, request for quote, required transactions, responsive quote, resting bids, RFQ, RFQ response period, RFQ system, Rulebook, SB SEF, security-based swap execution facility, SEF trading platforms, SEFs, SIFMA, single joint transactions, sporadic liquidity, swap data repositories, swap execution, swap execution facilities, timing delay, trading venues, transparency, voice-based system, voice-based trading, widened bid/offer spreads,
From: MFA, Stuart Kaswell

To:

David Stawick, CFTC
Gary Gensler, Michael Dunn, Bart Chilton, Jill Sommers, Scott O'Malia, (all) CTFC.

MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. In our letter, MFA: (i) recommended that the CFTC apply approved objective, transparent criteria to determine when a SEF can make a swap available to trade; (ii) requested that the CFTC expand temporary grandfather relief for venues seeking to become SEFs; (iii) supported permitting SEFs to use both request for quote and order book systems, but encouraged the CFTC to permit the minimum number of recipients to whom a quote-requesting market participant must send an RFQ to be as low as one; and (iv) commented on the fifteen-second timing delay required for crossing and matching of trades.

Downloads