Footnote 88 sef rules and guidelines

23 Jan 2018 Skip to Search; Skip to Main Menu; Skip to Main Content; Skip to Footer to grant exemptions from the SEF Regulations if the CFTC determines that . The CFTC notes in FN 88 of the preamble to 17 CFR Part 37 that trading 30 Oct 2013 The biggest impact of Footnote 88 was felt among FX trading platforms, many of which had assumed they would not be required to register as8 Jul 2015 The CFTC's implementing regulation (the “SEF rule”) focuses on platforms Footnote 88 in SEF rule: Registration requirement applies to 4 Jun 2013 107/Tuesday, June 4, 2013/Rules and Regulations. 1 See Commodity section 2(h)(7). 93 The Commission notes that footnote 423 below. 18 Dec 2013 The derivatives industry has been up in arms over this little footnote that to voice trading as a result of the CFTC-SEF rules coming into force. 23 Dec 2013 The footnote expands the scope of the SEF mandate to effectively include all its own book by bemoaning the effects of the new regulations. Originally, those rules were thought to apply only to transactions that would be required to trade on a SEF. However, confusion over Footnote 88 and the 5 Nov 2018 adoption and/or codification of many existing staff guidance documents and staff The proposed rules would apply the statutory SEF registration requirement to execution requirement (i.e., codification of footnote 88 issue). Footnote 88 in the rules text has expanded the scope of who needs to register as to be “Required Transactions” under part 37 of the Commission's regulations, 23 Sep 2013 However, interpretation of "footnote 88" buried on page 22 of the CFTCs final SEF rules published in July is causing seemingly frantic dialogue