FIA Files Comment Letter on Proposed Position Limits Rule (Feb 7, 2014)
On Feb. 7 FIA filed a 48-page comment letter in response to the CFTC’s proposed position limits rule. FIA said that various aspects of the proposed rule would have a “negative impact” on price discovery and liquidity and would “significantly restrict” the ability of market participants to rely on the derivatives markets to hedge risk. FIA urged the CFTC to defer imposing position limits until after it has collected and analyzed the data necessary to make an empirical finding that 1) speculative position limits are “necessary” to “diminish, eliminate or prevent” the burden on interstate commerce caused by excessive speculation, and 2) that the proposed limit levels are “appropriate”. FIA also urged the CFTC to modify the proposal in a number of ways, and commented that there are less costly and less restrictive alternatives to the proposed compliance and reporting requirements that would still achieve the CFTC’s objectives, and urged the CFTC to adopt a number of specific changes if it decides to proceed with the proposed rule.
FIA Files Comment Letter on Proposed Aggregation Rule (Feb. 6, 2014)
On Feb. 6 FIA filed a 19-page comment letter in response to the CFTC’s proposed rule regarding the aggregation of positions. FIA said it generally supports the proposal because it incorporates or addresses many of the comments and recommendations made by FIA and other market participants concerning prior proposed amendments to the aggregation rules. In particular FIA said it supports the recognition that certain types of ownership structures should be exempted from aggregation. FIA also urged the CFTC to provide a “reasonable transition period” after the rule is finalized and recommended a number of additional clarifications and amendments to address the practical impact of the proposed rule.
FIA Requests Confirmation of Interpretation of CFTC Rule 1.73 Regarding SEFs and Bunched Orders (Jan. 31, 2014)
On Jan. 31 FIA submitted a letter to CFTC staff seeking confirmation that Rule 1.73 does not apply to agency-executed transactions on swap execution facilities. "Because the clearing FCM has the opportunity to screen the agency-executed swap transaction on a SEF for compliance with its limits before the transaction is executed and accepted for clearing, the executing agent has no need to screen swap orders for compliance with these limits," FIA wrote.
FIA also requested confirmation that bunched orders will not be subject to a provision in Rule 1.73 that applies to “give-ups” involving individual customers. FIA explained that because bunched orders involve multiple customers and do not identify at the time of execution the customers on whose behalf the order is executed or the amount of the order that is due to a particular customer, an initial clearing firm would not be able to apply and screen an individual customer limit.
FIA Issues Statement on Leadership Change at FOA (Jan. 13, 2014)
Washington, D.C.—Jan. 13, 2014—Walt Lukken, President and CEO of FIA and FIA Global, issued the following statement regarding the Futures and Options Association’s announcement of a change in leadership.
Click Here for FIA Statement
Click Here for FOA Statement
FIA Responds to CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading (Dec. 11, 2013)
Washington, D.C. - Dec. 11, 2013 - The Futures Industry Association today submitted an extensive response to the Commodity Futures Trading Commission’s Concept Release on Risk Controls and System Safeguards for Automated Trading. The response describes the many risk controls and system safeguards that are currently in use in the futures industry, and outlines several principles for the CFTC to consider as it examines ways to further strengthen those controls and safeguards. The response also contains detailed responses to specific questions posed by the CFTC in its concept release, and draws on the collective expertise of nearly 100 individuals from members of FIA and the FIA Principal Traders Group.
FIA Concept Release Response - Press Release
FIA Concept Release Response - Comment Letter
Futures Industry Releases Insurance Study (Nov. 15, 2013)
CME Group, Futures Industry Association, the Institute for Financial Markets and National Futures Association today announced the release of a study on the economic feasibility of adopting an insurance regime for the U.S. futures industry.
Customer Asset Protection Insurance Study
FIA Global Holds First Board Meeting; Names Jackie Mesa as Executive Director (Nov. 7, 2013)
FIA Global, the new organizational structure that brings together the Futures Industry Association in Washington, the Futures and Options Association in London, and FIA Asia in Singapore, passed a key milestone today when it held its first face-to-face board meeting and began setting its work priorities for the coming year.
FIA Special Report: CFTC Approves Position Limit and Aggregation Proposals (Nov. 5, 2013)
The Commodity Futures Trading Commission on Nov. 5 approved a proposed position limits rule and a proposal determining when positions held by two or more related entities should be aggregated. The proposed position limit rule is intended to implement a directive in the Dodd-Frank Act to harden and extend the existing position limit regime. If finalized, the rule would establish position limits for futures and options on 28 physical commodities and several hundred economically equivalent swaps.
FIA Special Report
FIA Special Report: CFTC Approves Final Customer Protection Rules (Oct. 31, 2013)
The Commodity Futures Trading Commission on Oct. 30 held a public meeting to consider the CFTC’s enhanced customer protection rules. Earlier in the day, the CFTC approved two Dodd-Frank related rules via seriatim.
FIA Special Report
Full Text of CFTC Rules, Background Information, FAQs and CFTC Statements
FIA Statement on CFTC Customer Protection Rule (Oct. 31, 2013)
The Futures Industry Association today issued a statement regarding the Commodity Futures Trading Commission’s final rule on customer protections.
Click Here for Statement
FIA Comments on CME’s Proposed Elimination of EFRP Trades (Oct. 25, 2013)
On Oct. 25, the Futures Industry Association filed a comment letter with the Commodity Futures Trading Commission in response to a proposal from CME Group to eliminate the use of transitory exchange-for-related-position (EFRP) transactions and make various other changes to CME’s Rule 538. In its letter FIA asked the CFTC to defer consideration of CME’s proposal until after the CFTC issues rules implementing the trade execution requirement in Core Principle 9 as well as rules related to block futures trades. By considering all of these rules together, regulators will be better able to coordinate the rules and avoid inhibiting access to futures markets, particularly with respect to less liquid markets.
Click Here for Comment Letter