SIFMA and joint trades provided comments to the Office of the Comptroller of the Currency, Federal Housing Finance Agency, Federal…
Mr. Christopher Kirkpatrick
U.S. Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, D.C. 20581
Re: Supplemental Notice of Proposed Rulemaking on Regulation Automated Trading (“Supplemental Proposal”), RIN 3038-AD521
Dear Mr. Kirkpatrick:
The Futures Industry Association (“FIA”), FIA Principal Traders Group (“FIA PTG”), International Swaps and Derivatives Association (“ISDA”), Managed Funds Association (“MFA”),
Securities Industry and Financial Markets Association (“SIFMA”), SIFMA Asset Management Group (“AMG”), U.S. Chamber of Commerce (the “Chamber”) Center for Capital Markets Competitiveness (“CCMC”), and the Commodity Markets Council’s (“CMC”) (collectively, the “Group”2) memberships include executing and clearing members, swap dealers, trading firms, investment managers, end users, and exchanges that will be directly impacted by the U.S. Commodity Futures Trading Commission’s (“CFTC”or the “Commission”) Notice of Proposed Rulemaking on Automated Trading (“Regulation AT”)3 and related proposed rulemakings, including the most recent Supplemental Proposal. We respectfully request that the Commission extend the comment deadline for the Supplemental Proposal by 180 days in order to accommodate the complexity of this particular suite of new automated trading regulations as well as the
imminent period of transition at the Commission.
While we commend the Commission and CFTC Staff for attempting, in a thorough and detailed fashion in the Supplemental Proposal, to respond to and in certain places adopt earlier comments on the proposed automated trading rules, commenters and yet-to-be appointed Commissioners need sufficient time to understand and assess the new and interrelated aspects of this uniquely complex supplemental rulemaking.