Tag Archives: SEF

Breaking: CFTC Certifies the First MAT Submission

By Andrew Cross and Tom Watterson Attention investment managers, banks, CPOs, insurance companies and anyone who currently must clear their interest rate swaps, the requirement to trade interest rate swaps on a swap execution facility ("SEF") will come into force on February 15, 2014. Part 1: What will be covered by the trading mandate? The … Continue Reading

CFTC Provides Time Limited Relief to Oral Recordkeeping Requirements for CTAs — UPDATE to: One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements

By Andrew Cross and Tom Watterson In our November 1, post “One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements” we sought to raise awareness regarding increased recordkeeping requirements for SEF members under CFTC Rule 1.35(a). CFTC Rule 1.35(a) generally requires “members” of a SEF (or an exchange) to maintain oral records (i.e., … Continue Reading

One Consequence of Becoming a SEF Member – Increased Recordkeeping Requirements

We wanted to raise awareness on a point that has not received much attention to date: increased recordkeeping requirements for SEF members. At the outset, many SEFs use the term “participant” synonymously with “member.” So, if you are one of the many swap market participants who have received a “Participant Agreement” in the past month, then this … Continue Reading

CFTC Taking Comments on Requiring Interest Rate Swaps to be Executed on SEFs or DCMs

By Andrew Cross and Tom Watterson On Friday, Javelin SEF made the first “Made Available to Trade” submission (an “MAT Submission”) to the CFTC for certain interest rate swaps. Javelin’s submission, if not objected to by the CFTC, would cause those interest rate swaps come under the trading requirement, and those swaps would then be … Continue Reading

Breaking- CFTC Staff Offers Relief from Reporting and SEF Rulebook Enforcement Obligations In a Series of Letters

By Andrew Cross and Tom Watterson Last night the CFTC Division of Market Oversight (“DMO”) released CFTC Letters 13-55, 13-56, and 13-57. CFTC Letters 13-56 and 13-57 are particularly relevant for market participants other than SEFs. CFTC Letter 13-55 provides no-action relief to the SEFs for compliance with the Part 43 reporting obligations and the … Continue Reading
LexBlog