No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclo...

Summary: No-action position for registered swap dealers and major swap participants that enter into certain swaps referencing the Secured Overnight Financing Rate (described in the letter) relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission regulation 23.431(a)(3)(i).

CFTC LETTER NO. 24-02 NO-ACTION FEBRUARY 20, 2024

Market Participants

Division

Amanda L. Olear

Director

Re:

Request for No-Action Position for Swap Dealers and Major Swap Participants

Regarding the Obligation to Provide a Pre-Trade Mid-Market Mark for Certain

Transactions Referencing the Secured Overnight Financing Rate

Ladies and Gentlemen:

This letter responds to a request (“Request”) received by the Market Participants Division

(“MPD”) of the Commodity Futures Trading Commission (“CFTC” or “Commission”) from the

Alternative Reference Rates Committee’s (“ARRC”) regulatory working group subcommittee and

its member firms (“ARRC RWG”), in which ARRC RWG requested that MPD provide a no-

action position similar to that in CFTC Staff Letter 12-581 (“Letter 12-58”) for registered swap

dealers and major swap participants (“Swap Entities”) that enter into certain overnight index

swaps (“OIS”) referencing the Secured Overnight Financing Rate (“SOFR”) without disclosing a

pre-trade mid-market mark (“PTMMM”) to the counterparty of the transaction as required under

§ 23.431(a)(3)(i),2 as further described below.3

I.

Background

A.

Regulatory Background

Section 4s(h)(3)(B) of the Commodity Exchange Act (“CEA”)4 directs the Commission to

adopt business conduct standards for Swap Entities that:

1 See CFTC Staff Letter 12-58 (Dec

arket mark (“PTMMM”) to the counterparty of the transaction as required under

§ 23.431(a)(3)(i),2 as further described below.3

I.

Background

A.

Regulatory Background

Section 4s(h)(3)(B) of the Commodity Exchange Act (“CEA”)4 directs the Commission to

adopt business conduct standards for Swap Entities that:

1 See CFTC Staff Letter 12-58 (Dec. 18, 2012), Re: Request for Relief Regarding Obligation to Provide Pre-Trade

Mid-Market Mark for Certain Credit Default Swaps and Interest Rate Swaps, available at

https://www.cftc.gov/LawRegulation/CFTCStaffLetters/letters.htm. All other CFTC staff letters referenced in this

letter are also available on the Commission’s website.

2 17 CFR 23.431(a)(3)(i).

3 MPD understands that the ARRC and ARRC RWG dissolved after making the Request, however, ARRC RWG’s

representatives have informed the Commission that the former members wish to continue with the request.

4 7 U.S.C. § 6s(h)(3)(B).

U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre

1155 21st Street, NW, Washington, DC 20581

Telephone: (202) 418-5000

No-Action Position re: SOFR PTMMM

2

require disclosure by the swap dealer or major swap participant to any counterparty to the

transaction (other than a swap dealer, major swap participant, security-based swap dealer,

or major security-based swap participant) of –

* * *

(iii) (I) for cleared swaps, upon the request of the counterparty, receipt of the daily

mark of the transaction from the appropriate derivatives clearing organization; and

(II) for uncleared swaps, receipt of the daily mark of the transaction from the swap

dealer or the major swap participant.5

On February 17, 2012, the Commission published final rules prescribing certain business

conduct standards for Swap Entities,6 which included § 23.431.7 In relevant part, § 23.431 reads

as follows:

At a reasonably sufficient time prior to entering into a swap, a swap dealer or major swap

participant shall discl

aily mark of the transaction from the swap

dealer or the major swap participant.5

On February 17, 2012, the Commission published final rules prescribing certain business

conduct standards for Swap Entities,6 which included § 23.431.7 In relevant part, § 23.431 reads

as follows:

At a reasonably sufficient time prior to entering into a swap, a swap dealer or major swap

participant shall disclose to any counterparty to the swap (other than a swap dealer, major

swap participant, security-based swap dealer, or major security-based swap participant)

material information concerning the swap in a manner reasonably designed to allow the

counterparty to assess . . . [t]he material incentives and conflicts of interest that the swap

dealer or major swap participant may have in connection with a particular swap, which

shall include: (i) [w]ith respect to disclosure of the price of the swap, the price of the swap

and the mid-market mark of the swap as set forth in paragraph (d)(2) of this section…8

In describing the purpose of requiring Swap Entities to disclose the PTMMM, the

Commission stated that “the spread between the quote and mid-market mark is relevant to

disclosures regarding material incentives and provides the counterparty with pricing information

that facilitates negotiations and balances historical information asymmetry regarding swap

pricing.”9,10

5 Id.

6 See Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties, 77 FR 9734

(Feb. 17, 2012) (“Final Business Conduct Standards”).

7 17 CFR 23.431. In the proposed business conduct standards rules, the Commission proposed § 23.431 to “provide

specificity with respect to certain material information that must be disclosed” by Swap Entities. Business Conduct

Standards for Swap Dealers and Major Swap Participants with Counterparties, 75 FR 80638, 80643 (proposed Dec.

22, 2010) (“Proposed Business Conduct Standards”)

rds”).

7 17 CFR 23.431. In the proposed business conduct standards rules, the Commission proposed § 23.431 to “provide

specificity with respect to certain material information that must be disclosed” by Swap Entities. Business Conduct

Standards for Swap Dealers and Major Swap Participants with Counterparties, 75 FR 80638, 80643 (proposed Dec.

22, 2010) (“Proposed Business Conduct Standards”).

8 Final Business Conduct Standards at 77 FR 9824.

9 Id. at 9766.

10 In the preamble to the proposed rule, the Commission noted that the “mid-market [mark] is a transparent measure

that would assist counterparties in calculating valuations for their own internal risk management purposes,”

Proposed Business Conduct Standards at 75 FR 80646.

No-Action Position re: SOFR PTMMM

3

B.

Letter 12-58

On December 18, 2012, the Commission’s Division of Swap Dealer and Intermediary

Oversight (“DSIO” and now, MPD) published Letter 12-58 in response to a request from the

International Swaps and Derivatives Association, Inc. (“ISDA”). ISDA requested, and DSIO

granted, a no-action position relating to the requirement under § 23.431(a)(3)(i)11 to provide a

PTMMM to certain counterparties for certain swaps, including interest rate swaps:

(A) in the “fixed-for-floating swap class” (as such term is used in § 50.4(a)12)

denominated in USD or EUR,

(B) for which the remaining term to the scheduled termination date is no more than

30 years, and

(C) that have the specifications set out in the § 50.413 (“Covered Rates Derivative

Transactions”).14

In support of its request, ISDA argued that Covered Rates Derivative Transactions are

highly-liquid, exhibit narrow bid-ask spreads, and are widely quoted by Swap Entities in the

marketplace.15 ISDA further noted that in light of these and other factors, compliance with the

PTMMM requirement does not provide any significant informational value and would require

adding further operational capabilities that may add significant costs for Swap Entities while

delayi

ansactions are

highly-liquid, exhibit narrow bid-ask spreads, and are widely quoted by Swap Entities in the

marketplace.15 ISDA further noted that in light of these and other factors, compliance with the

PTMMM requirement does not provide any significant informational value and would require

adding further operational capabilities that may add significant costs for Swap Entities while

delaying trade times for their counterparties.16

C.

Market Transition from LIBOR to SOFR

In response to significant concerns regarding the reliability and robustness of LIBOR and

other interbank offered rates (collectively, “IBORs”), the Financial Stability Board (“FSB”) called

for the identification of alternative benchmarks to the IBORs and transition plans to support

11 17 CFR 23.431(a)(3)(i).

12 17 CFR 50.4(a).

13 17 CFR 50.4.

14 See Letter 12-58 at 3–5. Covered Rates Derivative Transactions included certain swaps referencing the London

Interbank Offered Rate (“LIBOR”).

15 Id. at 3.

16 Id.

No-Action Position re: SOFR PTMMM

4

implementation.17,18 The U.S. Financial Stability Oversight Council (“FSOC”) made repeated

calls for member agencies to work closely with market participants to identify and mitigate risks

that may arise during an IBOR transition process.19

In 2014, the Federal Reserve Bank of New York convened ARRC in order to identify best

practices for U.S. alternative reference rates, identify best practices for contract robustness,

develop an adoption plan, and create an implementation plan with metrics of success and a

timeline. In June 2017, ARRC identified a broad Treasuries repo financing rate, SOFR, as the

preferred alternative benchmark to U.S. Dollar LIBOR (“USD LIBOR”) for certain new U.S

RC in order to identify best

practices for U.S. alternative reference rates, identify best practices for contract robustness,

develop an adoption plan, and create an implementation plan with metrics of success and a

timeline. In June 2017, ARRC identified a broad Treasuries repo financing rate, SOFR, as the

preferred alternative benchmark to U.S. Dollar LIBOR (“USD LIBOR”) for certain new U.S.

Dollar derivatives and other financial contracts.20 It also published an updated “Paced Transition

Plan” outlining the steps that ARRC, central counterparties, and other market participants would

take in order to help build the liquidity required to support the issuance of, and transition to,

contracts referencing SOFR.21 In accordance with ARRC’s Paced Transition Plan,22 trading of

SOFR-based derivatives and other financial contracts linked to alternative benchmarks

commenced in 2018 and has since expanded in scope.23 While USD LIBOR’s use as an interest

17 See generally FSB Statement, Interest rate benchmark reform: Overnight risk-free rates and term rates (July 12,

2018), available at https://www.fsb.org/2018/07/interest-rate-benchmark-reform-overnight-risk-free-rates-and-

term-rates/; see FSB Statement, Reforming Major Interest Rate Benchmarks (July 22, 2014), available at

https://www.fsb.org/wp-content/uploads/r_140722.pdf; see International Organization of Securities Commissions

(“IOSCO”) Final Report, Principles for Financial Benchmarks (July 2013), available at

https://www.iosco.org/library/pubdocs/pdf/IOSCOPD415.pdf

ark-reform-overnight-risk-free-rates-and-

term-rates/; see FSB Statement, Reforming Major Interest Rate Benchmarks (July 22, 2014), available at

https://www.fsb.org/wp-content/uploads/r_140722.pdf; see International Organization of Securities Commissions

(“IOSCO”) Final Report, Principles for Financial Benchmarks (July 2013), available at

https://www.iosco.org/library/pubdocs/pdf/IOSCOPD415.pdf.

18 See FSB Statement, Interest rate benchmark reform: Overnight risk-free rates and term rates, at 1–2 (“Because

derivatives represent a particularly large exposure to certain IBORs, and because these prospective [risk-free rate]

RFR-derived term rates can only be robustly created if derivatives markets on the overnight RFRs are actively and

predominantly used, the FSB believes that transition of most derivatives to the more robust overnight RFRs is

important to ensuring financial stability.”).

19 See e.g., FSOC Statement, 2018 Annual Report, 4–5, 8–9, 108–109 (Dec. 19, 2018), available at

https://home.treasury.gov/system/files/261/FSOC2018AnnualReport.pdf. See FSOC Statement, 2013 Annual

Report, 6, 14–15, 137, 140–142 (June 2013), available at

https://www.treasury.gov/initiatives/fsoc/Documents/FSOC%202013%20Annual%20Report.pdf (“The uncertainty

surrounding LIBOR’s sustainability may threaten individual financial institutions and the U.S. financial system

more broadly. Specifically, without advance preparation, a sudden cessation of such a heavily used reference rate

could cause considerable disruptions to, and uncertainties around, the large flows of LIBOR-related payments. It

could also impair the functioning of a variety of markets, including business and consumer lending …. The Council

recommends that member agencies work closely with market participants to identify and mitigate risks from

potential dislocations during the transition process.”)

ce rate

could cause considerable disruptions to, and uncertainties around, the large flows of LIBOR-related payments. It

could also impair the functioning of a variety of markets, including business and consumer lending …. The Council

recommends that member agencies work closely with market participants to identify and mitigate risks from

potential dislocations during the transition process.”).

20 See ARRC, Press Release (June 22, 2017), available at

https://www.newyorkfed.org/medialibrary/microsites/arrc/files/2017/ARRC-press-release-Jun-22-2017.pdf.

21 See ARRC, Second Report at 17⁠–24 (March 5, 2018), available at

https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2018/ARRC-Second-report.

22 See ARRC, 2019 Incremental Objectives, available at

https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2019/ARRC_2019_Incremental_Objectives.pdf.

23 See e.g., ARRC, SOFR: A Year in Review (Apr. 2019), available at

https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2019/SOFR_Anniversary.pdf. See also ISDA,

Interest Rate Benchmarks Review: Full Year 2018 and the Fourth Quarter of 2018 (Jan. 2019), available at

https://www.isda.org/a/xogME/Benchmarks-Full-Year-2018.pdf.

No-Action Position re: SOFR PTMMM

5

rate derivatives benchmark has declined substantially,24 SOFR has become the prevailing interest

rate derivatives benchmark.25

II.

Request for No-Action Letter

ARRC RWG submits that the rationale underlying Letter No. 12-58 and the no-action

position provided to Swap Entities entering into Covered Rates Derivative Transactions is equally

applicable to certain OIS which reference SOFR (“SOFR OIS”), and that relief from the PTMMM

requirement should therefore be extended to such SOFR OIS

derivatives benchmark.25

II.

Request for No-Action Letter

ARRC RWG submits that the rationale underlying Letter No. 12-58 and the no-action

position provided to Swap Entities entering into Covered Rates Derivative Transactions is equally

applicable to certain OIS which reference SOFR (“SOFR OIS”), and that relief from the PTMMM

requirement should therefore be extended to such SOFR OIS. Specifically, ARRC RWG

represents that the rationale underlying Letter 12-58—that the benefits of a PTMMM are minimal

for liquid swaps with publicly-available price information, and that providing a PTMMM is costly

and may adversely affect counterparties—is now true of these SOFR OIS and will be increasingly

true in the wake of the transition to SOFR OIS. Therefore, ARRC RWG requests that a Swap

Entity not be required to disclose a PTMMM in connection with interest rate swaps: (1) in the

“overnight index swap class” (as such term is used in § 50.4(a)26) denominated in USD; (2)

referencing the SOFR floating rate index; (3) for which the remaining term to the scheduled

termination date is no more than 50 years; and (4) that have the specifications set out in § 50.427

(“Covered SOFR OIS”).

In support of its request, ARRC RWG notes that the SOFR OIS market continues to serve

as the prevailing benchmark of the interest rate swaps market28 and is widely quoted by dealers

on- and off-facility, with real-time tradable bid and offer prices made available electronically via

trading facilities, including via multiple swap execution facilities. In addition, ARRC RWG states

that the implementation and familiarity of market participants with part 4329 real-time reporting

requirements provides an additional source for readily available pricing data to market

participants.30 ARRC RWG also observes that the Commission itself has affirmed that SOFR OIS

24 In March 2021, the U.K

acilities. In addition, ARRC RWG states

that the implementation and familiarity of market participants with part 4329 real-time reporting

requirements provides an additional source for readily available pricing data to market

participants.30 ARRC RWG also observes that the Commission itself has affirmed that SOFR OIS

24 In March 2021, the U.K. Financial Conduct Authority (“FCA”) confirmed that certain IBOR settings would either

cease to be provided by any administrator or would no longer be representative for the one-week and two-month

USD LIBOR settings, immediately after December 31, 2021, and for all other USD LIBOR settings, immediately

after June 30, 2023. See FCA Statement, Announcement on Future Cessation and Loss of Representativeness of the

LIBOR Benchmarks (March 5, 2021), available at https://www.fca.org.uk/publication/documents/future-cessation-

loss-representativeness-libor-benchmarks.pdf.

25 See Request at 5 and Appendix A for additional information evidencing the growth of SOFR’s usage in swaps

markets.

26 17 CFR 50.4(a).

27 17 CFR 50.4.

28 See ARRC, March 9 Meeting Readout (March 9, 2023), available at

https://www.newyorkfed.org/medialibrary/Microsites/arrc/files/2023/ARRC-Readout-March-2023-Meeting.pdf

(finding that SOFR-linked interest rate swaps have consistently accounted for more than 85% of daily average risk

traded in the interest rate swaps market since June 2022.).

29 17 CFR part 43.

30 See 17 CFR 43.3(a)(2) and (3) (requiring that executed trades and pricing information, including the interest rate

benchmark, i.e. the “spread” data element, be publicly available “as soon as technologically practicable” after

rest rate swaps have consistently accounted for more than 85% of daily average risk

traded in the interest rate swaps market since June 2022.).

29 17 CFR part 43.

30 See 17 CFR 43.3(a)(2) and (3) (requiring that executed trades and pricing information, including the interest rate

benchmark, i.e. the “spread” data element, be publicly available “as soon as technologically practicable” after

No-Action Position re: SOFR PTMMM

6

is highly traded, liquid, and produces or makes available accessible pricing data. Specifically,

ARRC RWG notes that when the Commission extended swap clearing requirements to cover

SOFR OIS,31 the Commission considered and affirmed that SOFR OIS presents, in relevant part,

“the existence of significant outstanding notional exposures, trading liquidity, and adequate pricing

data.”32

ARRC RWG notes that the Commission has supported the transition to SOFR in other

actions. In particular, ARRC RWG notes that the Commission has implemented a series of no-

action letters that eased the transition from LIBOR-referencing interest rate swaps to SOFR-

referencing interest rate swaps.33 These no-action letters have generally provided no-action

positions for SOFR-referencing swaps related to uncleared margin and external business conduct

standards,34 trade execution,35 clearing,36 and trade reporting requirements.37 A separate no-action

position related to futures commission merchants’ investment of customer funds “in permitted

investments that contain an adjustable rate of interest that is benchmarked to SOFR”38 was also

issued.

execution. Real-time reporting creates a publicly accessible and historical record of pricing data for SOFR OIS

promptly after trade execution.).

31 See Clearing Requirement Determination Under Section 2(h) of the Commodity Exchange Act for Interest Rate

Swaps To Account for the Transition From LIBOR and Other IBORs to Alternative Reference Rates, 87 FR 52182

(Aug

execution. Real-time reporting creates a publicly accessible and historical record of pricing data for SOFR OIS

promptly after trade execution.).

31 See Clearing Requirement Determination Under Section 2(h) of the Commodity Exchange Act for Interest Rate

Swaps To Account for the Transition From LIBOR and Other IBORs to Alternative Reference Rates, 87 FR 52182

(Aug. 24, 2022) (modifying the Commission’s interest rate swap clearing requirement by removing the requirement

to clear interest rate swaps referencing LIBOR and other IBORs and replacing them with clearing mandates for

interest rate swaps referencing overnight RFRs, including OIS referencing SOFR.).

32 See section 2(h)(2)(D)(ii) of the CEA, 7 U.S.C. 2(h)(2)(D)(ii).

33 See e.g., CFTC Staff Letters 21-26 (Dec. 20, 2021), Re: Revised No-Action Positions to Facilitate an Orderly

Transition of Swaps from Inter-Bank Offered Rates to Alternative Benchmarks; 21-27 (Dec. 20, 2021), Re:

Extension of Certain Staff No-Action Relief from the Trade Execution Requirement to Facilitate an Orderly

Transition from Inter-Bank Offered Rates to Alternative Risk-Free Rates; 21-28 (Dec. 20, 2021), Re: Revised Staff

No-Action Relief from the Swap Clearing Requirement for Amendments to Legacy Uncleared Swaps to Facilitate

an Orderly Transition from Inter-Bank Offered Rates to Alternative Risk-Free Rates; 21-30 (Dec. 22, 2021), Re: No-

Action Position With Respect to Certain Requirements of Parts 43 and 45 for Registered Entities and Swap

Counterparties Reporting Swap Data for LIBOR Swaps That Will Transition to Risk-Free Rates; and 22-21 (Dec.

31, 2022), Re: CFTC Regulation 1.25 – Investment of Customer Funds in Securities with an Adjustable Rate of

Interest Benchmarked to the Secured Overnight Financing Rate – Extension of Time-Limited No-Action Position

Concerning Investments by Futures Commission Merchants and No-Action Position Concerning Investments by

Derivatives Clearing Organizations.

34 See CFTC Staff Letter 21-26

21 (Dec.

31, 2022), Re: CFTC Regulation 1.25 – Investment of Customer Funds in Securities with an Adjustable Rate of

Interest Benchmarked to the Secured Overnight Financing Rate – Extension of Time-Limited No-Action Position

Concerning Investments by Futures Commission Merchants and No-Action Position Concerning Investments by

Derivatives Clearing Organizations.

34 See CFTC Staff Letter 21-26.

35 See CFTC Staff Letter 21-27.

36 See CFTC Staff Letter 21-28.

37 See CFTC Staff Letter 21-30.

38 See CFTC Staff Letter 21-02 (Jan. 4, 2021), Re: CFTC Regulation 1.25 – Investment of Customer Funds – Time-

Limited No-Action Position for Investments in Securities with an Adjustable Rate of Interest Benchmarked to the

Secured Overnight Financing Rate, as extended by CFTC Staff Letter 22-21.

No-Action Position re: SOFR PTMMM

7

III.

MPD No-Action Position

After carefully considering the request, MPD believes that a no-action position is warranted

in relation to the PTMMM requirement for Covered SOFR OIS. Accordingly, MPD will not

recommend that the Commission take an enforcement action against a Swap Entity for its failure

to disclose the PTMMM, as required by § 23.431(a)(3), to a counterparty in a Covered SOFR OIS,

provided that: (1) real-time tradeable bid and offer prices for the Covered SOFR OIS are available

electronically, in the marketplace, to the counterparty; and (2) the counterparty to the Covered

SOFR OIS agrees in advance, in writing, that the Swap Entity need not disclose a PTMMM for

the Covered SOFR OIS.

MPD is providing this no-action position based on, among other things, ARRC RWG’s

representations that Covered SOFR OIS benefit from a combination of high liquidity, narrow bid

and offer spreads, and the existence of a significant amount of publicly available information with

respect thereto

grees in advance, in writing, that the Swap Entity need not disclose a PTMMM for

the Covered SOFR OIS.

MPD is providing this no-action position based on, among other things, ARRC RWG’s

representations that Covered SOFR OIS benefit from a combination of high liquidity, narrow bid

and offer spreads, and the existence of a significant amount of publicly available information with

respect thereto. MPD will continue to monitor market data with respect to the liquidity of, bid and

offer spreads for, and publicly available information on Covered SOFR OIS, and if the

circumstances change, MPD may limit, impose additional or different conditions on, or revoke

this no-action position. MPD notes that this no-action position is applicable only with respect to

Covered SOFR OIS and does not apply to any obligations of a Swap Entity to disclose PTMMMs

for contracts other than the Covered SOFR OIS or to any other Commission regulation, including,

without limitation, the requirement to provide a daily mark pursuant to § 23.431(d).39 However,

MPD may consider extending this no-action position to other transactions, if sufficient data and

other relevant information are submitted to MPD establishing the appropriateness of an

extension.40

This letter, and the position taken herein, represent the views of MPD only, and do not

necessarily represent the position or view of the Commission or of any other office or division of

the Commission. This letter and the no-action position taken herein are not binding on the

Commission.41 Further, this letter, and the positions taken herein, are based upon the facts and

circumstances presented to MPD staff. Any different, changed or omitted material facts or

circumstances might render the position taken in this letter void. Finally, as with all staff letters,

MPD retains the authority to condition further, modify, suspend, terminate, or otherwise restrict

the terms of the position taken herein, in its discretion

ions taken herein, are based upon the facts and

circumstances presented to MPD staff. Any different, changed or omitted material facts or

circumstances might render the position taken in this letter void. Finally, as with all staff letters,

MPD retains the authority to condition further, modify, suspend, terminate, or otherwise restrict

the terms of the position taken herein, in its discretion.

Should you have any questions, please do not hesitate to contact Frank Fisanich, Chief

Counsel, at (202) 418-5949; or Jacob Chachkin, Associate Chief Counsel, at (202) 418-5496.

39 17 CFR 23.451(d).

40 Any requests to extend this relief to other transactions should be submitted, along with data and other relevant

information, in accordance with § 140.99, 17 CFR 140.99.

41 See § 140.99(a)(2), 17 CFR 140.99(a)(2) (“A no-action letter binds only the issuing Division . . . and not the

Commission or other Commission staff.”).

No-Action Position re: SOFR PTMMM

8

Sincerely,

_______________________

Amanda L. Olear

Director

Market Participants Division

cc:

Regina Thoele, Compliance

National Futures Association, Chicago