Improve CFTC Swaps Trading Framework

MFA urges policymakers to make targeted improvements to the legal framework for trading over-the-counter derivatives on registered swap execution facilities (SEFs) to enhance the observed benefits of the current framework, including increased pre-trade price transparency, price competition, and liquidity. MFA supports an innovative SEF marketplace that offers investors more flexibility in how they trade swaps, provided that all market participants have true impartial access to the available trading protocols, and requirements for pre-trade price transparency, price competition, and multiple-to-multiple execution are preserved.