Global Correspondence
GFMA and MFA Submit Comments to the CFTC and SEC on Safe Harbor Provisions for the Definition of Eligible Contract Participants
GFMA’s Global Foreign Exchange Division (GFXD) and the Managed Funds Association (MFA) submit a proposed safe harbor to the CFTC’s proposed rule interpreting the definition of “eligible contract participant” (ECP) contained in the Commodity Exchange Act (the “CEA”). We urge the CFTC and the SEC to adopt the Proposed Safe Harbor as a new final paragraph of the Proposed CFTC ECP Rule.