CFTC's Proposed Revision of SEF Trade Execution Requirements

March 18, 2019 Eric Juzenas

The U.S. Commodities Futures Trading Commission (CFTC) published proposed revisions to the regulations of swap execution facilities (SEFs) at the end of 2018. Chatham Financial provided comment on these proposed revisions, supporting the CFTC's intent to bring more transactions onto SEFs while providing insight into several shortcoming that could negatively impact the bespoke swaps market end users.


Disclosures

Chatham Hedging Advisors, LLC (CHA) is a subsidiary of Chatham Financial Corp. and provides hedge advisory, accounting and execution services related to swap transactions in the United States. CHA is registered with the Commodity Futures Trading Commission (CFTC) as a commodity trading advisor and is a member of the National Futures Association (NFA); however, neither the CFTC nor the NFA have passed upon the merits of participating in any advisory services offered by CHA. For further information, please visit https://www.chathamfinancial.com/legal-notices/.

Transactions in over-the-counter derivatives (or “swaps”) have significant risks, including, but not limited to, substantial risk of loss. You should consult your own business, legal, tax and accounting advisers with respect to proposed swap transaction and you should refrain from entering into any swap transaction unless you have fully understood the terms and risks of the transaction, including the extent of your potential risk of loss. This material has been prepared by a sales or trading employee or agent of Chatham Hedging Advisors and could be deemed a solicitation for entering into a derivatives transaction. This material is not a research report prepared by Chatham Hedging Advisors. If you are not an experienced user of the derivatives markets, capable of making independent trading decisions, then you should not rely solely on this communication in making trading decisions. All rights reserved. 19-0084

About the Author

Eric Juzenas

Eric is Chatham Financial's Global Head of Compliance and Regulation. He advises on derivatives regulatory compliance and legal documentation, including regulatory advisory, ISDA negotiation, pre- and post-trade compliance processes, and standalone regulatory technology solutions for clients, including reporting, valuations, portfolio reconciliation, and collateral management. He covers both US and European regulations. Eric has advised a range of clients including senior government officials, Members of Congress, and financial and commercial firms on derivatives regulation and compliance. He has played a central role in derivatives policy, helping write and implement portions of the Dodd Frank Act and working on several reauthorizations of the US Commodity Futures Trading Commission (CFTC). He has also participated in international policy and regulatory efforts with the European Union, Financial Stability Board, and the International Organization of Securities Commissions (IOSCO). At the CFTC, he was a deputy to the US Financial Stability Oversight Council. Prior to Chatham, Eric worked at Bloomberg, LP in their Global Regulatory Policy Group covering US and European regulation. Previously, he spent eleven years at CFTC in a variety of roles including Chief of Staff, Chief Operating Officer and Senior Counsel to Chairman Gary Gensler, Commissioner Michael V. Dunn and Commissioner Sharon Y. Bowen. He began his career in derivatives spending six years as Deputy Chief Counsel and Counsel to the US Senate Agriculture, Nutrition and Forestry Committee where he was responsible for writing and advising on derivatives legislation and policy. Eric graduated from the University of Wisconsin-Madison with a degree in Philosophy and certificate in Integrated Liberal Studies. He holds a law degree from the George Washington University Law School, and a masters degree in Environmental/Occupational Health from the Milken Institute School of Public Health at George Washington University.

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