SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on comments on Industry Filing IF 14-003 (ICE SEF Filing) and related issues concerning the application of “made available to trade” (MAT) determinations to package transactions.

In addition, SIFMA identifies certain issues that would be raised by requiring package transactions involving futures contracts or securities to be executed on a designated contract market (DCM) or swap execution facility (SEF), including issues raised by proposed revisions to Chicago Mercantile Exchange (CME) Rule 538.

Finally, SIFMA expresses support for permitting the execution of package transactions subject to the rules of a SEF, as proposed in the ICE SEF Filing, which would facilitate the orderly implementation of the mandatory trading requirement contained in the Commodity Exchange Act (CEA), as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).