Global Correspondence

GFMA Submits Comments to the CFTC Requesting No-Action Relief Relating to SEF Confirmations

The Global Foreign Exchange Division (GFXD) of GFMA, on behalf of Bloomberg SEF LLC, ICE Swap Trade, LLC, INFX SEF, Inc.,  MarketAxess SEF Corporation,  SwapEx, LLC, TeraExchange, LLC,  360T Trading Networks Inc.,  and Thomson Reuters (SEF) LLC,  provides comments to the Division of Marketing Oversight of  Commodity Future Trading Commission (CFTC) requesting that the Division confirm that it will not recommend that the Commission commence an enforcement action against a swap execution facility (SEF) that has failed prior to January 1, 2015 to comply with the requirements of Commission regulations in connection with swap transactions executed on the SEF that are not required or intended to be submitted for clearing (Non-Cleared Swaps), provided that the SEF has complied with the conditions applicable to it under this letter.

GFXD believes that, if granted, the no-action relief (NAR) requested in this correspondence would largely mitigate the legal uncertainties that have contributed to the continued reluctance on the part of market participants to trade Non-Cleared Swaps on SEFs, and would help foster an orderly transition to the SEF marketplace for Non-Cleared Swaps as the Interdivisional Working Group completes its work.

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