MFA Submits Letter to CFTC on SEF Onboarding Documentation Issues

On January 8, MFA submitted a letter as a request for action by the CFTC to conduct targeted compliance reviews of the rulebooks and user agreements of temporarily registered swap execution facilities (SEFs), and to enforce the CFTC SEF rules and related staff guidance before the effective date of the first “made available-to-trade” (MAT) determination.  In requesting such action, MFA outlined the material issues that MFA members have encountered related to SEF rulebooks, SEF user agreements, and operational and documentation readiness for SEF trading of bunched orders in credit default swaps that represent significant barriers to impartial access for buy-side firms to SEFs.  MFA’s letter also raised certain further documentation and commercial challenges that buy-side firms have faced in negotiating access to SEFs that represent a principal impediment to funds completing the SEF onboarding process.