Swap Execution Facilities Regulation - Comment Letter - Morgan Stanley - February 7, 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 7, 2012

From the comment letter:

“Morgan Stanley believes it is critical to preserve liquidity in the swap markets. Our primary concern is that the Proposed Rules will make swap markets less liquid and more risky for our customers and ourselves. The Proposed Rules do not stand alone. They will interact with other rules that have yet to be finalized. We would be less concerned about the MAT determination if the Commission’s rules on permissible trading protocols and block sizes were liberal. Unfortunately, we believe the opposite is likely to be true. Restrictive trading protocols and large block sizes, in combination with the Proposed Rules, will be even more harmful to liquidity, in our view.”


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