Parameters for Large Notional Off-Facility Swaps & Block Trades

SIFMA and the International Swaps and Derivatives Association, Inc. provide comments to the Commodity Futures Trading Commission (CFTC) on proposed procedures to establish appropriate minimum block sizes for large notional off-facility swaps and block trades, CFTC RIN 3038–AD08.  The proposal would set forth criteria for grouping swaps into separate swap categories, the methodology for setting appropriate minimum block sizes, and measures to prevent the public disclosure of the identities, business transactions and market positions of swap market participants in order to implement certain statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which amends the Commodity Exchange Act (CEA). The associations believe the development of appropriate minimum block sizes to be of critical importance to the successful implementation of the real-time public reporting obligation in the Dodd-Frank Act and rules recently adopted by the CFTC, and offer their recommendations relating to this proposal.