MFA Submits Comment Letter to CFTC on Proposed Process for Making a Swap Available to Trade

MFA submitted a comment letter to the CFTC in response to its proposed process for designated contract markets (DCMs) and swap execution facilities (SEFs) to make a swap available to trade (MAT). In the letter, MFA recommended to the CFTC that the MAT determination process should be a separate process from the CFTCs process for review of swaps for mandatory clearing, with a 90-day implementation period before a final MAT determination becomes effective. We also recommended that the CFTC should establish a clear process for determining when a swap is no longer available to trade on a DCM or SEF using their proposed trading and liquidity-related factors for consideration of a swaps MAT-eligibility. Finally, MFA suggested that the definition of an economically equivalent swap should be eliminated from both processes.