GFMA Submits Comments to the CFTC on Real-time Public Reporting of Swap Transaction Data

14 May 2012

GFMA provides comments to the Commodity Futures Trading Commission (CFTC) on real-time public reporting of swap transaction data, RIN 3038-AD08 – 17 CFR Part 43. In the proposed rulemaking, the CFTC asks for specific data and analysis to support the block trades proposal. At this time, it is difficult to provide such statistical analysis given that there are no central bodies responsible for collecting sufficiently granular detail – an issue that swap data repositories (SDRs) are in part intended to address. GFXD therefore advocates an approach that allows the CFTC flexibly to assess the appropriate methodologies for determining swap categories, block sizes and cap sizes.

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