External Meetings: SEC/CFTC Meeting with MFA

"The MFA is a hedge fund trade group who's constituency is primarily single manager hedge funds. The following topics were discussed: (1) The definition of Swap Dealer and Major Swap Participant. The MFA concerned about how broadly Swap dealer can be interpreted. They are hoping only institutions that engage in a more traditional dealer capacity will be labeled as Swap Dealer and tests were discussed that might identify what parties act in this dealer capacity. The concept of ""bright line"" tests for Swap Dealers and Major Swap Participant were discussed; (2) Clearing and Confirmation. The discussion focused on confirmation and clearing in the credit derivative space. The MFA is largely in favor of central clearing. They would like the margin regime to be clear and transparent with additional ownership to collateral established. The requirements for becoming a clearing member were also talked about; (3) SEFs and Transaction Reporting. The structure of SEFs were discussed in regards to innovation and quote gathering. Transaction reporting and the concept of a block trade were addressed as well."