External Meetings: Meeting with ICE

ICE discussed the timing of the clearing and trading mandates.  ICE suggested that swaps clearing should be based upon an open offer model, not novation.  ICE also discussed the need for pre-trade clearing member level risk checks for Swap Execution Facilities (SEF) as in the proposal for DCMs.  ICE had asked questions about how the Request for Quote (RFQ) provisions of the SEF rulemaking worked.  ICE also and discussed the timing of implementing swap data repositories.  CFTC staff and ICE also discussed the definitions of swap dealer and major swap participants as those terms relate to the energy markets.