MFA Letter to CFTC on Proposed DCO General Provisions and Core Principles

September 13, 2019

From: MFA

To:

Commondity Futures Trading Commission

MFA submitted a letter to the Commodity Futures Trading Commission (CFTC) on the CFTC’s proposed rules on  ““Derivatives Clearing Organization General Provisions and Core Principles”.  In the letter, MFA applauds the CFTC for the proposed amendments to Part 39 that would permit “fair and open access” to DCOs and allow for customer representation on a DCO’s board, default committee, and other governing bodies.  To enhance the efficacy of the proposed rules and to ensure that the views of all participants in the cleared derivatives markets are taken into account, MFA requests that the CFTC:

  1. Affirmatively mandate inclusion of customers on DCO default committees and governing bodies; and
  2. Encourage the CFTC to retain the proposed “fair and open access” mandate as a catalyst for breaking down the barriers to customers becoming direct DCO members.

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