Antidisruptive Practices Authority

SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on an advance notice of proposed rulemaking (ANPR) relating to antidisruptive practices authority contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), RIN 3038-AD26, 75 Fed. Reg. 67301.  The groups respond to the CFTC’s solicitation for comments on Section 747 of the Dodd-Frank Act, which amends Section 4c(a) of the Commodity Exchange Act by prohibiting certain trading practices deemed disruptive of fair and equitable trading on or subject to the rules of a regulated entity. The groups share their two primary concerns with respect to Section 747 of the Dodd-Frank Act and the CFTC’s rulemaking under it.