MFA respectfully encourages the Commission to adopt the Proposed Rule as proposed. The amendment would expand risk-management opportunities and harmonize the treatment of economically comparable futures products while preserving appropriate regulatory oversight.
MFA explains:
- The Rule would eliminate an unnecessary distinction between EU debt futures and futures on economically comparable foreign-government debt, broaden access to useful risk management tools, and reduce operational friction.
- The amendment would address the current asymmetry between futures on EU debt obligations and futures on debt issued by designated EU Member States, while improving market access, hedging opportunities, market depth, and competition.
- The Rule would expand access to an important risk-management tool for U.S. market participants, including MFA members with exposures to EU debt obligations and related European fixed-income markets.
