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Ex Parte Meeting for Proposed Rule 75 FR 76139

  • Title:
    Meeting with Markit

    Ex Parte No: 275
    Date: 6/7/2011

    Meeting Date:

    Tuesday, June 7, 2011

    CFTC Staff:

    Jeff Steiner
    Carl Kennedy
    Tom Leahy
    Aaron Miller
    Laurie Gussow
    Dan McKeever
    Stephen Kane

    Organization(s):

    Markit

    External Attendees:

    Marcus Schueler (Markit)
    Allison Kelrick (Markit)

    Additional Information:

    On June 7, 2011, staff met with Markit to discuss various aspects of their comment letters relating to real-time reporting. 
    Method of Public Dissemination
    Markit mentioned that the CFTC’s real-time proposal would lead to more fragmentation than the SEC’s proposal since the SEC’s proposal mandates public dissemination through an SDR.  Markit suggests that real-time reporting should be mandated through an SDR (giving the SDR the ability to delegate the dissemination to a third party).
    Normalization of Pricing
    Markit also discussed their views on how to deal with pricing for situations where there is no standardization – mentioned the idea of converting to equivalents.
    Condition Flags
    Markit stated that displaying a risk category as part of public dissemination will not help; however displaying a price for credit risk would be more helpful.  There should be a condition flag for index arbitrage swaps (where one leg is an index and the other leg is the single names in the index).
    Harmonizing Reporting with the SEC
    Markit stated that harmonization is particularly important for index swaps.

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