Comment Text:
Meeting with Barclays Capital
Wednesday, January 19, 2011
Memo from
Zaidi, Amir
CFTC Staff :
Richard Shilts
Riva Spear Adriance
Nancy Markowitz
Mauricio Melara
Amir Zaidi
Nadia Zakir
Swati Shah
David Kass
Jane Croessmann
Steven Seitz
Anthony Hays
Frank Fisanich
Greg Price
Aaron Miller
Mike Penick
Dominique Collins
External Attendees :
Allison Parent (Barclays)
Sonali Das Theisen (Barclays)
Keith Bailey (Barclays)
Deirdre Dunn (Barclays)
Alex Guest (Barclays)
Additional Information :
On January 19, 2011, CFTC Staff met with members of Barclays Credit & Rates, Commodity Compliance, and Government Policy groups. During the meeting, Barclays asked Staff several questions and had several comments related to the SEF NPRM as follows: (i) Request for quote (RFQ) systems – Barclays commented that there should be some accommodation to the requirement that RFQs go out to 5 market participants. Especially in illiquid markets, this requirement could weaken liquidity and hurt prices. One participant may be proper for less liquid products. Staff requested that Barclays submit a comment letter on this topic; (ii) Swaps made available for trading – Barclays commented that the number of participants should be considered when assessing whether a swap is available for trading. Staff requested that Barclays submit a comment letter on this topic; (iii) 15 second delay provision in Section 37.9(b)(3) – Barclays raised the concern about a third party stepping ahead of a second party with respect to the 15 second delay provision. The delay may provide market participants with an incentive to wait for information. Staff requested that Barclays submit a comment letter and request clarification on this topic.
