Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - Swaps & Derivatives Market Association - August 8, 2011

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Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

From the comment letter: "The SDMA supports the proposed rules which take proven elements from the futures markets and apply them to the cleared swap markets. Allowing customers to effect efficient and low latency transactions is critical to ensure the success of the cleared swap market.

Using bunched trades promotes execution and operational efficiency. Bunched trades can be allocated on a post trade basis, as they are today in both bilateral and exchange traded environments.

The necessity of maintaining risk controls mandates that bunched trade allocation can be complete by the end of the trading day. In order for this process to maintain the integrity of trades and not create undue latency, bunched trades must be treated like all trades with an immediate confirmation of trade detail at point of execution and upon real time acceptance into clearing. By utilizing existing technology, the monitoring of risk and the management of margin is consistent across vertically designed execution and clearing venues as well as horizontally designed systems thus allowing for the application of efficient work flow such as post-execution trade allocations."


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