MFA Comment Letter to CFTC on Proposed Clearing Requirement Determination

The MFA submitted this comment letter in response to the CFTC's proposed clearing requirement determination rulemaking, expressing its strong support for the CFTC's decision to focus on certain classes of credit default swaps (CDS) and interest rate swaps in its initial clearing requirement determination. The MFA went on to express concerns specific to the iTraxx Europe CDS indices.

Essentially, the MFA says that (as to any product that is required to be cleared) there must be a period of time in which clearing is voluntarily available to all customers, so that customers can test the operation of a system, before it is made mandatory.

View letter here(links externally to MFA website).

See next item.