Antidisruptive Practices Authority Proposed Interpretive Order

SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on an antidisruptive practices authority proposed interpretive order.  The CFTC proposal seeks to provide interpretive guidance to the three statutory disruptive practices prohibited by Section 747 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) which amends Commodity Exchange Act (CEA) Section 4c(a)(5).  The groups believe the proposal does not go far enough in offering guidance to market participants, and is still unclear as to what constitutes proscribed, violative conduct. The groups offer observations and recommendations to help the CFTC meet the goals of the guidance.