Comment Text:
Kepos Capital LP
November 25, 2013
Via Electronic Submission: http://comments.cftc.gov
Ms. Melissa Jurgens
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street NW
Washington, DC 20581
RE: Industry Filings: IF 13-004 , IF 13-005 , and IF 13-007
Certifications to Implement Made Available-to-Trade Determinations for Certain Interest Rates Swaps from each of Javelin SEF, trueEX, and TW SEF
Dear Ms. Jurgens:
Kepos Capital LP is pleased to provide comments to the Commodity Futures Trading Commission on the certifications from each of Javelin SEF, trueEX, and TW SEF to implement Made Available-to-Trade (“MAT”) determinations for certain Interest Rate Swaps (“IRS”).
We endorse the recommendations made in the Managed Funds Association’s November 21st comment letter, and believe that the Commission should adopt a phased implementation of the MAT determinations that focuses initially on the benchmark tenors in the relevant classes of swaps and uses a data-driven approach to prioritize the inclusion of non-benchmark tenors as well as package transactions in subsequent implementation phases. A similar phased implementation approach successfully facilitated the market’s transition to mandatory central clearing, and is warranted again to ensure a smooth and seamless transition to the mandatory trading of certain IRS on swap execution facilities and designated contract markets.
We appreciate the opportunity to provide comments on the MAT certifications. Please feel free to contact the undersigned at [email protected] with any questions regarding these comments.
Respectfully,
/s/ Simon Raykher
General Counsel and Chief Compliance Officer
