Swap Execution Facilities Regulation - Comment Letter - ICAP North America - March 8, 2011

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Dodd-Frank Timeline, Core Principles for SEFs, CFTC
Final Rule Issue Effective Date Compliance Date
June 4, 2013 August 5, 2013 October 2, 2013 (one-year phase-in of RFQ minimum); Also see No-action relief note

Core Principles for SEFs, CFTC
March 8, 2011

ICAP requests that the Commission revise the Proposed Rules to reflect the following:

  • The SEF definition should be construed more broadly;
  • Each SEF should be permitted to specify its own methods of execution;
  • SEFs should have reasonable discretion in relation to block trades;
  • SEFs should have greater flexibility in establishing governance structures;
  • SEFs should be permitted to establish their own rule enforcement mechanisms, disciplinary procedures and sanctions; [and]
  • SEFs should have a significant time period to comply with the final rules.


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