Time-Limited No-Action Relief Relating to SEF Confirmations

SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting for time-limited no-action relief relating to confirmations for swaps not required or intended to be cleared.

The relief requested in the joint Swap Execution Facility (SEF)-Global Financial Exchange Division (GFXD) of GFMA letter intends to establish a transitional confirmation and reporting protocol, and to establish a relationship between specific economic transaction terms and non-transaction specific relationship terms consistent with conventional documentation architecture used throughout the financial markets, while ensuring that these arrangements support the Commission’s public and regulatory transparency requirements and do not facilitate the circumvention of Commission regulatory reporting requirements or SEF rules through bilaterally negotiated documentation terms.

SIFMA joins the SEFs and GFXD in urging the Division of Market Oversight to provide time-limited no-action relief requested in the joint SEF-GFXD letter.