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CFTC Proposed Revision SEF Trade Execution Requirements

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March 15, 2019 Mr. Christopher Kirkpatrick Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington, D.C. 20581 Re: Swap Execution Facilities and Trade Execution Requirement; Proposed Rule – RIN 3038-AE25, 83 Fed. Reg. 61946 (Nov. 30, 2018) Introduction Chatham Hedge Advisors ("Chatham") appreciates the opportunity to submit these comments on the proposed revisions to the regulations of swap execution facilities ("SEFs") and the trade execution requirement ("Proposal") published by the U.S. Commodity Futures Trading Commission ("CFTC" or "Commission") on November 30, 2018. 1 Chatham Hedge Advisors is a wholly-owned subsidiary of Chatham Financial Corp., an employee-owned, global provider of derivatives, financial, and regulatory services. Our market- leading advisory practitioners provide trusted support in risk and debt management including interest rate, FX, commodity hedging, hedge accounting, regulatory compliance, capital advisory, and defeasance. Chatham helps its clients arrange and execute 6,000 swaps per year. A pioneer in developing intelligent tools to support our practitioners in critical risk management tasks, Chatham offers an advanced technology SaaS platform that supports our thriving risk management practice and is accessible to clients directly via ChathamDirect™. Our platform supports multiple asset classes with tools for quantitative analysis, sophisticated scenario modeling, accounting workflows, valuations, reporting, and regulatory compliance. Chatham is registered with the National Futures Association ("NFA") and Commission as a Commodity Trading Advisor ("CTA") and is registered with the Securities and Exchange Commission as a Municipal Advisor. The Proposed Rule Developing rules to improve the integrity and transparency of the swaps marketplace while streamlining regulation is complicated by the diversity of products, strategies, and execution 1 Swap Execution Facilities and Trade Execution Requirement; Proposed Rule, 83 Fed. Reg. 61946 (Nov. 30, 2918), available at https://www.cftc.gov/sites/default/files/2018-11/2018-24642a.pdf.

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