Letter to CFTC on Proposed Prohibition on Post-Trade Name Give-Up

On March 2, MFA submitted a comment letter to the CFTC on the CFTC’s proposed rule on post-trade name give-up on swap execution facilities (Name Give-Up).  In our letter, MFA strongly supported the proposed rule and urged the CFTC to proceed with its prompt adoption.  In particular, MFA expressed among other things that:

  1. Name Give-Up contravenes the impartial access mandate under Dodd-Frank and CFTC rules;
  2. Name Give-Up is an anti-competitive practice, whose elimination would improve pre-trade price transparency, liquidity, and competition;
  3. There is no legitimate basis for Name Give-Up since central clearing and straight-through processing have eliminated potential counterparty exposure; and
  4. Elimination of Name Give-Up would not adversely affect the prices on name-disclosed request-for-quote systems.