Swap Execution Facilities Regulation - Comment Letter - Managed Funds Association - February 13, 2012

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Timeline, Made Available to Trade Provisions
Final Rule Issue First MAT Determination First Compliance Date
June 4, 2013 January 16, 2014 February 15, 2014

Process for a Designated Contract Market or Swap Execution Facility to Make a Swap Available to Trade
February 13, 2012

MFA respectfully suggests that the Proposed Rules would be strengthened and improved by:

  • Ensuring the MAT determination is distinct and supplemental to the review of swaps for mandatory clearing
  • Strengthening the review process of whether or not a swap should continue to be available to trade
  • Eliminating the provisions related to the definition of an “economically equivalent swap”

References

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