MFA has proactively engaged in advocacy with the goal of eliminating the two-tier market and the practice of post-trade name give-up. MFA urges policymakers to improve the legal framework for trading over-the-counter derivatives on registered SEFs by adopting rule changes that would allow investors more flexibility in how they trade swaps.

CFTC rules require certain swap to be executed on a swap execution facility (SEF). SEF execution is supposed  to be beneficial to market participants by providing various methods of execution (e.g., central limit order book, RFQ, etc.). In practice, the current SEF regime has proven problematic for buy-side market participants as a two-tier market has developed where some SEFs cater to dealers trading with other dealers, while some SEFs facilitate trading between dealers and clients.