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Response to the CFTC Staff Letter 25-05
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Re: CFTC Staff Letter 25-05
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We were excited to see emerging clarity that the CFTC Staff Action represented by letter 25-05, which withdraws Staff Advisory 21-19, may bring to the swaps market. Further clarity around what may trigger SEF registration should assist in facilitating the use of technology and innovation to provide more transparency to qualified swaps market participants in executing their swaps hedge transactions without triggering SEF registration. Consistently, we hear about concerns from corporates and other swaps market hedgers about “spoofing,” “fading,” and “being the product” that arise from certain technology options that are in use today. The Staff Action is the first step in what we hope will accommodate the rapid repositioning of capital and technology to provide more transparent hedging execution solutions that are fully aligned with corporate hedgers and consistent with more clear regulatory requirements.


