Comment Text:
Meeting with WMBA
Wednesday, February 23, 2011
Memo from
Steiner, Jeffrey L.
CFTC Staff :
Gary Gensler
Tom Leahy
Megan Sperling
Riva Adriance
Tom Leahy
George Pullen
Rick Shilts
Jeff Steiner
Mauricio Melara
Amir Zaidi
External Attendees :
Stephen Merkel (BGC Cantor)
Ed Brown (ICAP)
Christopher Ferreri (ICAP)
Julian Harding (Tradition)
Christopher Giancarlo (GFI)
William Shields (GFI)
Shawn Bernardo (Tullett Prebon)
Brian Donnelly (Tullett Prebon)
Micah Green (Patton Boggs)
Matthew Kulkin (Patton Boggs)
Additional Information :
On February 23, 2011, the WMBA discussed the contents of their comment letter relating to the real-time public reporting notice of proposed rulemaking. With regard to the block trade formula, the WMBA stated that a 3x multiple works for some markets but not for others and that the multiple should be asset classe specific. The WMBA suggested using industry expertise to develop a matrix and proposed that an advisory committee be set up to make these determinations. With regard to the block trade time delay, the WMBA stated that we just do not know what an adequate amount of time is for block trades and that there should be SEC/CFTC coordination.
