FIA PTG submitted comments to the CFTC on the Swap Dealer De Minimis Exception Preliminary Report, focusing on the Report section entitled “Swaps Executed on a SEF or DCM and/or Cleared.”
The letter noted that FIA PTG members face significant barriers to providing liquidity in SEF or DCM-traded and cleared swaps markets.
Specifically, the letter supports the exclusion of SEF or DCM-traded and cleared swaps from an entity’s de minimis calculation, given that exchange traded and cleared swaps achieve the regulatory goals of swap dealer regulation without any further regulatory action required.
