Last week, the Foreign Exchange Professionals Association (FXPA) submitted a comment letter to the Commodity Futures Trading Commission (CFTC) regarding its proposed rulemaking on SEF reforms. 

FXPA’s letter was focused on the need for the CFTC to exempt NDFs and exchange-traded or cleared swaps from de minimis threshold calculations as part of any SEF reform.  

As FXPA’s letter noted, “[E]xempting exchange-traded and cleared swaps from AGNA calculations can improve SEF and DCM market volume and liquidity…Such an action would be a market-oriented solution to the problem of low SEF volume and liquidity.” 

FXPA also expressed appreciation for the CFTC’s interest in comprehensively updating its SEF regulations, “which were last comprehensively reviewed over five years ago”.

FXPA’s comment letter can be found here.