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