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Ex Parte Meeting for Proposed Rule 75 FR 76139

  • Title:
    Teleconference with the WMBAA

    Ex Parte No: 310
    Date: 7/11/2011

    Meeting Date:

    Monday, July 11, 2011

    CFTC Staff:

    George Pullen
    Laurie Gussow

    Organization(s):

    BGC
    GFI Group
    ICAP
    Tradition
    Tullet Prebon
    Patton Boggs LLP
    Wholesale Market Brokers Association of America (WMBAA)

    External Attendees:

    Stephen Merkel (BGC)
    Jeff Letzler (BGC)
    J. Christopher Giancarlo (GFI)
    Pat McCarty (ICAP)
    Chris Ferreri (ICAP)
    Julian Harding (Tradition)
    Shawn Bernardo (Tullett Prebon)
    Micah Green (Patton Boggs LLP)
    Carolyn Walsh (Patton Boggs LLP)
    Matthew Kulkin (Patton Boggs LLP)
    Matthew Dunn (Patton Boggs LLP)

    Additional Information:

    On July 11, 2011, CFTC staff participated via teleconference in a meeting with members of the WMBAA.  WMBAA shared its views on the rulemaking for Real-time Public Reporting. 
     
    WMBAA discussed the impact of the Real-time Public Reporting rules on the industry.  Specifically, WMBAA raised its concerns in the designation of block trade sizes, as it believes that such designation will dramatically impact market liquidity.  In addition The WMBAA suggested several data studies to assist in the determination of block trade sizes, including studies on crossing networks and voice versus electronic trades.  WMBAA also suggested a testing period for the Real-time Public Reporting process, before actual implementation. 
     
    WMBAA also indicated its concern that the Commission’s rulemaking was too prescriptive in nature in proposing the mode of execution for all trades, with the exception of block trades.

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