The Managed Funds Association ("MFA") submitted a comment letter to the CFTC on the proposed rulemaking to modify the aggregation requirements under its position limits rules. The letter focused on the impact that the 2013 Aggregation Proposal ("the Proposal") would have on MFA members; specifically, how it would affect members that (i) utilize multiple independent trading strategies, (ii) may be invested in "owned entities," including operating companies that are not commodity pools, and/or (iii) may be "passive own ers in the funds of funds context." The letter stated that MFA generally

The Managed Funds Association ("MFA") submitted comments to the CFTC on its position limits for derivatives proposal. According to MFA, the CFTC "has not fulfilled its statutory obligation" to make a "necessity finding" that position limits are necessary or appropriate. The letter stated that rulemaking related to position limits should be "empirically driven and not a response to popular sentiment or partial analyses." While MFA voiced its overall disagreement with the need for position limits, it provided comments and suggestions to the CFTC on the proposed rule, including the following: the

The Futures Industry Association ("FIA") submitted a comment letter to the CFTC regarding the proposed rulemaking on Position Limits for Derivatives. According to the letter, FIA's comments focus on the impact of speculative position limits on "the public policy imperatives of protecting the price discovery and risk-management function of liquid and fair derivatives markets." According to the letter, FIA is concerned that various aspects of the Proposed Rule will negatively impact the price discovery function and liquidity of physical commodity and economically equivalent derivatives contracts

The CFTC announced measures to promote trading on swap execution facilities ("SEFs") and support an orderly transition to the mandatory trading of swaps, which begins for certain interest rate swaps on February 15, 2014. The CFTC stated that, in connection with the commencement of the trading mandate, the CFTC Division of Market Oversight ("DMO") took the following measures: In order to protect the identities of counterparties trading on SEFs and incentivize anonymous trading on regulated platforms, the CFTC issued an interim final rule to clarify the scope of "permissible access" by market

The CFTC held its 11th Technology Advisory Committee ("TAC") meeting on February 10, 2014. On three separate panels, the TAC, along with subcommittees on Automated and High-Frequency Trading and Data Standards, focused on various issues related to swap execution facility ("SEF") regulation. The agenda of the panels was as follows: Panel I – Data: Where Does the Commission Stand and How Do We Fix What's Broken? Panel II – Concept Release on Automated Trading Panel III – Made Available-to-Trade ("MAT") Determination In his opening statement, Commissioner O'Malia expressed his appreciation that