Made Available to Trade Submission by Bloomberg of Certain CDS and Interest Rate Swaps

SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity and Futures Trading Commission (CFTC) on the Made Available to Trade (MAT) submission by Bloomberg of certain credit default swaps (CDS) and interest rate swaps.

SIFMA supports the contract-by-contract approach taken by Bloomberg and Bloomberg’s approach to showing how it meets the listing requirement by demonstrating how it supports the trading of the submission swaps.

SIFMA also agrees with Bloomberg’s view that certain bespoke swaps, such as non-par swaps, should be excluded from the MAT determination. In addition, SIFMA requests that the CFTC address the cross-border and packaged swap issues that will become even more important as a result of a MAT determination.