Mr. Christopher Kirkpatrick
Secretary
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581

Re: Commodity Futures Trading Commission Title VII Swap Execution Facility and Trade Execution Regulatory Framework and Implementation

Dear Mr. Kirkpatrick:

The Securities Industry and Financial Markets Association (“SIFMA”) 1 appreciates the continuing efforts of the Commodity Futures Trading Commission (“CFTC” or “Commission”) and its staff in developing the swap execution facility (“SEF”) and related trade execution regulatory framework. We are supportive of the Commission’s continued efforts in seeking to facilitate further industry dialogue, most recently at a public roundtable on the “made available to trade” determination process, 2

We agree with Chairman Timothy Massad’s recent statement that, while the progress to date in developing a robust trade execution regime has been significant, the work is not finished.
in addition to considering past discussions and comments we have submitted aimed at informing topics relevant to the Commission’s work in this area. We therefore present the following comments, which are intended to identify areas of the regulatory framework that require further consideration in light of current market practice, or because they depend on temporary no-action relief letters to avoid causing severe market and trading disruption. In furtherance of contributing more sustained and lasting solutions to some of the remaining issues, these comments reflect our members’ concerns and experiences to date operating under the current Commission regulations and related temporary no-action relief.

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