Requesting Further Relief relating to the Execution of Package Transactions

SIFMA Asset Management Group (SIFMA AMG), in a letter to the Commodity Futures Trading Commission (CFTC), is requesting further relief from the trade execution requirement for package transactions.

In a no-action letter dated May 1, 2014, the Division of Market Oversight of the CFTC provided relief from the requirement to mandatorily execute certain package transactions on swap execution facilities (SEFs) or designated contract markets (DCMs) on a phased basis. The last phase of that relief is currently set to roll off on November 15, 2014 (Package Relief Expiration Date).

SIFMA AMG is requesting the Package Relief Expiration Date be deferred for an indefinite period until a sufficient showing of liquidity can be made for the integrated package transaction, or at least for a period of no less than six months, for the MAT component of all package transactions that would otherwise be mandated for SEF or DCM execution on November 15, 2014 (Exempt Package Transactions); at a minimum, SIFMA is requesting that the Division of Market Oversight provide this relief for the specific categories of Exempt Package Transactions.