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Markets Structure and Liquidity
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SEF Execution Methods and MAT Process
Treasury recommends that the CFTC:
- consider rule changes to permit swap execution facilities (SEFs) to use any means of interstate commerce to execute swaps subject to a trade execution requirement that are consistent with the “multiple-to-multiple” element of the SEF definition (CEA Section 1a(50)). Such rule changes should be undertaken in recognition of the statutory goals of impartial access for market participants and promoting pre-trade price transparency in the swaps market;
- reevaluate the MAT determination process to ensure sufficient liquidity for swaps to support a mandatory trading requirement; and
- consider clarifying or eliminating footnote 88 in its final SEF rules to address associated market fragmentation.
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