External Meetings: Call with Trabue Bland

Discussion on the meaning of the factors under “Permitted Transactions”  in proposed regulation 37.9(a)(1)(v) - (v) Permitted Transactions means transactions that meet any of these requirements: (A) Are block trades; (B) Are not swaps subject to the Act’s clearing and execution requirements, or~(C) Are illiquid or bespoke swaps. ~Trabue asked what “illiquid” meant as used in this paragraph; he thought it should be interpreted in a limited manner.  It was noted that clearinghouses may clear illiquid swaps as long as the swap can be priced, and so those swaps may be within the clearing mandate but not “made available for trading” (addressed in proposed regulation 37.10).  Trabue noted that swaps traded on ICE as both clearable and tradable.  A request was made that he send in his question and concern.