Release Number 8435-21

CFTC Orders California Company to Pay $100,000 for Failing to Register as a Swap Execution Facility

September 29, 2021

The Commodity Futures Trading Commission today issued an order filing and simultaneously settling charges against Symphony Communication Services, LLC for failing to register as a swap execution facility (SEF). The order requires Symphony to pay a $100,000 civil monetary penalty and to cease and desist from any further violations of the Commodity Exchange Act (CEA) and CFTC regulations, as charged.

Case Background

The order finds that from about July 2019 to March 2021, Symphony violated the SEF registration requirement by operating “SPARC Tool” on its communication platform. Symphony designed the web-based SPARC Tool to provide a technological tool for automated request for quote (RFQ) workflow for interest rate and cross currency swaps. SPARC Tool enabled multiple swap market participants to select swap product parameters, such as swap type, clearing preference, tenor, and notional size to populate RFQs. Those RFQs could be sent to multiple swap market participants. SPARC Tool then permitted swap market participants that received the RFQs to negotiate prices that could be acknowledged or confirmed using the command “done.” 

After the Division of Enforcement began an inquiry into Symphony’s unregistered activity, Symphony proactively identified and provided relevant information and thereafter took immediate steps to cease operation of its SPARC functionality. Accordingly, the civil monetary penalty is reduced to reflect Symphony’s substantial cooperation and remediation.

Division of Enforcement Staff responsible for this case are Ansley Schrimpf, Bryan Hsueh, Joseph Konizeski, Scott Williamson and Robert Howell. The Division of Market Oversight, and the Market Participants Division assisted in this matter.  


Customers and other individuals can report suspicious activities or information, such as possible violations of commodity trading laws, to the Division of Enforcement via a toll-free hotline 866-FON-CFTC (866-366-2382), file a tip or complaint online, or contact the Whistleblower Office. Whistleblowers are eligible to receive between 10 and 30 percent of the monetary sanctions collected paid from the Customer Protection Fund financed through monetary sanctions paid to the CFTC by violators of the Commodity Exchange Act.