Requesting Relief from the CFTC’s Trade Execution Requirement Compliance Date

The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief from the CFTC’s trade execution requirement compliance date.

Under current CFTC regulations, the trade execution requirement for a swap becomes effective 30 days after a “made available to trade” (MAT) determination for that swap is deemed approved or certified (the MAT Effective Date). To date, the Commission has received five MAT determination submissions and may require compliance with the trade execution requirement as soon as mid-February 2014.

SIFMA AMG requests the CFTC grant relief from the 30-day MAT Effective Date for market participants that are neither swap dealers (SDs) nor major swap participants (MSPs) (collectively non-SDs/MSPs) by not recommending enforcement action against any non-SD/MSP for non-compliance with a trade execution requirement for 90 days after the applicable MAT Effective Date.