Comment Text:
Memo from Aaron Brodsky
CFTC Staff: Rick Shilts, Riva Adriance, Megan Sperling, Nancy Markowitz, Mauricio Melara, Nadia Zakir, Mathew Hargrove, and Aaron Brodsky.
External Participants: Karl Cooper, Matthew Lisle, Lynn Martin, and Dawn Stump.
On April 14, 2011, Commission staff participated in a phone conference with representatives from NYSE Liffe US to discuss the proposed Core Principle 9 minimum centralized market trading requirement.
During the call, NYSE Liffe US reiterated many of the comments it set forth in its prior comment letter. In particular, NYSE Liffe expressed its opposition to the 85% threshold, claiming that off-exchange trading is often essential for new products to gain traction and that the 85% threshold will thus deter DCMs from launching new products. Staff suggested that NYSE Liffe submit further information as to the basis for the claim that new products need off-exchange trading to gain traction.
