Global Correspondence

GFMA Submits Letter on CFTC OpRes Proposed Framework

GFMA submitted a letter to the Commodity Futures Trading Commission (CFTC) on its rule proposal for requirements for an Operational Resilience (Op Res) Framework for Futures Commission Merchants, Swap Dealers, and Major Swap Participants.

GFMA believes that the Commission’s aim for a principles-based approach is consistent with other international regulatory efforts on operational resilience, which GFMA fully supports.

GFMA appreciates the importance of operational resilience for the public and private sectors to maintain confidence in the financial industry and support financial stability and economic growth.  GFMA and our members are fully committed to ensuring robust operational resilience and already deploy a wide variety of policies, procedures and controls to ensure “the ability to deliver critical operations through disruption.”  As such, we are keenly aware of the depth and breadth of work international regulators are currently doing in the operational resilience space and believe harmonization is in the interest of both regulators and firms.  These pre-existing frameworks are the product of not only recognition among our members that operational resilience is good for business, but also that many entities regulated by the Commission are already, or will shortly be, subject to operational resilience requirements that would overlap with those proposed by the Commission.  To that end, we have included an Appendix to this letter that highlights relevant regulations and guidance that financial firms already comply with globally and that reflect the resilience capabilities that firms have developed over time.

GFMA is also aware that the Securities Industry and Financial Markets Association (SIFMA) and the Institute of International Bankers (IIB) submitted a comment on the Proposal.  GFMA fully aligns and supports the recommendations in the SIFMA and IIB letter.


– 1 April 2024 –

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