Murphy & McGonigle CapitalMarketsReform.com - Core Principles

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Access to Capital

Public Companies and IPOs

Disproportionate Challenges for Smaller Public Companies

Expanding Access to Capital Through Innovative Tools

Maintaining the Efficacy of the Private Markets

Markets Structure and Liquidity

Securitization

Derivatives

Derivatives ...

Harmonization Between CFTC and SEC

Margin Requirements for Uncleared Swaps

CFTC Use of No-Action Letters

Cross-Border Issues

Capital Treatment in Support of Central Clearing

Swap Dealer De Minimis Threshold

Definition of Financial Entity

Position Limits

SEF Execution Methods and MAT Process

Swap Data Reporting

Financial Market Utilities

Regulatory Structure and Processes

Restoration of Exemptive Authority

Improving Regulatory Policy Decision Making

Self-Regulatory Organizations

International Aspects of Capital Market Regulation

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Recommendation

Policy Responsibility

Congress

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SEF Execution Methods and MAT Process

64.

SEF Execution Methods and MAT Process

CFTC

D, F

Proposed

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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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