SIA Submits Comments to the CFTC on a Petition by the London Clearing House Limited for an Exemption

The Over-the-Counter (OTC) Derivative Products Committee of the Securities Industry Association (SIA)* provides comments to the Commodity Futures Trading Commission (CFTC) on a petition by London Clearing House Limited (LCH) for an exemption under Section 4(c)(1) of the Securities Exchange Act of 1934 (the Exchange Act) in connection with LCH’s proposed “SwapClear” swap clearing activities. SIA urges the CFTC to grant the LCH petition for relief, and further urges the CFTC to clarify that requested relief is granted to the extent, and without any determination that, any swap transaction submitted for clearance by LCH constitutes a futures contract or commodity option subject tothe CFTC’s jurisdiction.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.