Back to Submissions

Letters

Proposed Process to Make Swaps Available to Trade

Issue

OTC Derivatives→

Summary

SIFMA, the Futures Industry Association (FIA) and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on the process by which swaps will be made “available to trade” and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which amends the Commodity Exchange Act (CEA).  The designation of a swap as “available to trade” will have broad ramifications for the market because such a swap will no longer be permitted to trade on a bilateral basis. As a result, an incorrect designation of “available to trade” would result in a decrease in liquidity, increase in costs and a decrease in the availability of hedges. The groups focus their collective views on five topic areas: Process, Factors to Consider, Reviews, Economically Equivalent Swaps and Effective Date.

PDF

Submitted To

CFTC

Submitted By

SIFMA, FIA, ISDA

Related Committee(s)

  • Swap Dealer Committee

Date

13

February

2012

Excerpt

Mr. David A. Stawick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21st Street, NW.
Washington, DC 20581

Re: CFTC RIN 3038-AD18 – Process for a Designated Contract Market or Swap Execution Facility to Make a Swap Available to Trade

Dear Mr. Stawick,

The International Swaps and Derivatives Association (“ISDA”), the Securities Industry and Financial Markets Association (“SIFMA”) and the Futures Industry Association (“FIA”)1 appreciate this opportunity to provide comments to the Commodity Futures Trading Commission (the “Commission”) regarding the recently released notice of proposed rulemaking and request for comments (“NPR”) concerning the process by which swaps will be made “available to trade” and the implementation of the related statutory provisions enacted by Title VII of the DoddFrank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), which amends the Commodity Exchange Act (the “CEA”).

Continue Reading >

More Submissions

Type:

Ryan LLC, et al. v. FTC

Court: U.S. District Court (N.D. Texas) Amicus Issue: Whether the FTC exceeded its statutory authority under the FTC Act by…

Type:

LKQ Corporation v. Rutledge

Court: Delaware Supreme Court Amicus Issue: Whether the Delaware Supreme Court’s holding in Cantor Fitzgerald precludes reviewing forfeiture-for-competition provisions for…