Comment Text:
Dear Sirs,
As a current user of EFPs on FX Futures contracts I believe this rule amendment will reduce the positive effects of using this mechanism and erode choice of execution venues.
Converting Spot FX transactions to futures contracts using this "transitory" mechanism allows users to migrate their trading risk away from unregulated FX markets to an exchange based environment with its superior settlement, margining and delivery structures while allowing for a choice of execution venues.
Thank You
John Wallace
