MFA Submits Supplemental Comment Letter to CFTC on “Made Available to Trade” Submissions

MFA submitted a supplemental comment letter to the CFTC in response to the amended Made Available-to-Trade (MAT) determinations of Javelin SEF, LLC and TW SEF LLC on November 29 for certain interest rate swap products.  MFA’s supplemental letter welcomes the revisions made by Javelin SEF and TW SEF in their amended MAT determinations.  With respect to outright swaps, the amended MAT determinations’ focus on spot-starting benchmark swaps is closely aligned with the scope MFA recommended in its November 21st comment letter to the CFTC for Day 1 SEF trading under our phase-in approach.  With respect to compound or package transactions, MFA generally supports the revisions and the statements made by TW SEF and Javelin SEF that their MAT determinations (i) do not apply to package transactions and (ii) do not apply to swaps that are executed as legs of package transactions.  MFA continues to believe that our phase-in approach will strike the appropriate balance by bringing the benefits of SEF trading to the most liquid products while ensuring that the migration to SEF trading does not inadvertently disrupt markets.  MFA notes that the SEFs themselves may well implement such a phase-in approach via a series of staggered MAT determinations.