MFA Submits Letter to CFTC on Proposed Wash Trade Advisory

MFA submitted a comment letter to the CFTC in response to comments on the CME Group’s proposed Market Regulation Advisory Notice on Wash Trades Prohibited.  In the letter, MFA expressed support for the CME Globex Self-Match Prevention functionality and provide additional suggestions for enhancing its functionality.  MFA also requested that the CME Group provide additional guidance, consistent with well-settled case law, and make clear that inadvertent self-matches by independent trading algorithms will not trigger wash trade liability just as inadvertent self-matches by independent decision makers will not trigger wash trade liability.