Swap Execution Facilities Regulation - Comment Letter - Wholesale Markets Brokers' Association, Americas (WMBAA) - April 4, 2011

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Dodd-Frank Timeline, Registration and Regulation of Security-Based Swap Execution Facilities, SEC
Proposal Date Comment Deadline Reopened Comment Period Deadline
February 28, 2011 April 4, 2011 July 22, 2013

Registration and Regulation of Security-Based Swap Execution Facilities, SEC
April 4, 2011 Summary of the WMBAA’s comments:

  • Support for the Commission’s flexible approach to evaluating applicant SB SEFs;
  • Support for the Commission’s interpretation of the SB SEF definition as it applies to trade execution through any means of interstate commerce, including request for quote (“RFQ”) systems, order books, auction platforms, or voice brokerage trading;
  • Explanation of the unique characteristics of OTC markets, particularly wholesale markets, and the unique regulatory framework that permits the many modes of swaps trade execution currently deployed by wholesale brokers;
  • Request that final rules allow ample time to allow platforms to transition to the new regime, in order to avoid market disruptions;
  • Support for a common regulatory organization (CRO) for SB SEFs to implement and facilitate compliance with the Commission’s rules; and
  • A reminder that the rules governing the core principles and other requirements for SEFs, in conjunction with the real-time public reporting of swap transaction data, must work collectively to ensure these markets retain their vibrancy in the future.

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