SIFMA AMG Submits Comments to CFTC Requesting Extended Relief Regarding the Execution of Package Transactions

SIFMA Asset Management Group ("SIFMA AMG") submitted a request for an extension of the relief from the trade execution requirement for package transactions beyond the expiration date provided by CFTC No-Action Letter 14-62.

Letter 14-62 provided relief to market participants executing swaps that are subject to the trade execution requirement but are also part of a "package transaction" from the requirement that these transactions must be executed on a swap execution facility ("SEF") or designated contract market ("DCM"). Furthermore, the letter provided a phased compliance timeline, with the last phase of relief set to roll off on November 14, 2014 ("Package Relief Expiration Date").

SIFMA AMG requested that the CFTC defer the Package Relief Expiration Date indefinitely or at least for a six-month period. SIFMA AMG requested that the deferral last until a "sufficient showing of liquidity can be made for the integrated package transaction." At a minimum, SIFMA AMG requested, the CFTC should permit the execution of MAT components of specific categories of Exempt Package Transactions to occur off of SEFs but remain subject to SEF rules.

See: Comment Letter.Related news: CFTC Provides No-Action Relief for "Package Transactions" (CFTC Letter 14-62) (with Patel Comment) (May 1, 2014); MFA Submits Request to CFTC for No-Action Relief from Trade Execution Requirement for Package Transactions (October 15, 2014); CFTC Hosts Public Roundtable on Trade Execution Requirement and Package Transactions (with Delta Strategy Group Summary) (February 13, 2014); CFTC Publishes Guidance, No-Action Letter and Interim Final Rule to Promote Trading on SEFs and Support an Orderly Transition to Mandatory Trading (CFTC Letter 14-12) (February 10, 2014); MFA Submits Letter to CFTC Requesting Relief for Package Transactions (January 27, 2014); MFA Submits Suggestions to CFTC on MAT Submissions (with Lofchie Comment) (November 25, 2013); SIFMA and ISDA Criticize SEFs' Made-Available-to-Trade Submissions (with Lofchie Comment) (November 21, 2013).