FIA filed a comment letter with the CFTC responding to the agency’s proposed rulemaking on Swap Execution Facility Requirements and Real-Time Reporting Requirements. FIA’s comments ask that the CFTC clarify a discrete, but important, part of the rule addressing a clearing FCM’s obligations under CFTC Rule 1.73 for block trades that are executed away from the SEF and then subsequently submitted for clearing. To that end, FIA provided suggested text in its letter that would provide FCMs with the needed legal clarity.
