SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on core principles and other requirements for swap execution facilities (SEFs) and the implementation of the related provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), RIN 3038-AD18.  The groups recommend the CFTC take a flexible approach focused on broad principles aimed at risk reduction, increased transparency and market integrity, rather than imposing detailed requirements, to allow for a smoother transition toward use of SEFs and uninterrupted operation of the swaps market within this new context.