Requesting No-Action Relief with Respect to the Clearing Requirement for iTraxx CDS Indices

The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief in regards to the clearing requirement for the iTraxx Europe, iTraxx Crossover and iTraxx HiVol credit default swap indices (collectively, iTraxx indices).  Under the CFTC clearing determination, swaps referencing iTraxx indices would be required to be cleared 60 days after they are available on a clearinghouse.  The group and its members expected to have to clear swaps referencing the iTraxx indices when made available by the Chicago Merchantile Exchange (CME).

However, CME told many SIFMA AMG members that they would not be ready to clear these instruments this year, while the IntercontinentalExchange (ICE) announced its readiness to clear these swaps.  The group requests that its members be given more time to clear iTraxx indices.  SIFMA AMG requests the CFTC to provide relief until at least 90 days after CME is able to provide customer clearing of iTraxx indices.  If the CFTC is not willing to extend the requested relief indefinitely, the AMG asks the CFTC to extend the compliance date for clearing iTraxx indices until no earlier than September 11, 2013.