External Meetings: Definitions Meeting with MFX Solutions

CFTC staff participated in a meeting with MFX Solutions, Inc. (“MFX”), a microfinance industry collaboration that supports microfinance lending in developing markets by supporting currency hedging in those markets. MFX expressed that, given the small total notional and average contract amounts, and the purpose of the swap activity they are engaged in, they should not be considered a “Swap Dealer” for the purposes of the rulemaking. MFX stated that when entities are under contractual or other restrictions to restrict their swap activities to certain types of swaps and certain types of counterparties, the decision of whether the entity is a swap dealer should take account of those restrictions. In the event it was ultimately considered to be a “Swap Dealer,” MFX expressed a concern regarding the clearing requirement considering its collateral is primarily composed of a guarantee from the Overseas Private Investment Corporation, a U.S. government agency.