Public Statements & Remarks

Opening Statement of Commissioner Caroline D. Pham before the Market Risk Advisory Committee

July 10, 2023

Thank you Commissioner Johnson, Marilee Dahlman, and everyone else who helped arrange today’s meeting.  I would also like to extend my thanks to the Members and Subcommittee Members of the Market Risk Advisory Committee (MRAC), along with the presenters, for your time and dedication to advising the Commission and sharing your expertise. Your service makes all of this possible.

There is an incredible agenda for today’s meeting.  Over the next almost three hours, the agenda includes all of the following:  the launch of workstreams for four subcommittees; discussion topics including central counterparty risk and governance, interest rate benchmark reform, market structure, and climate-related risk, innovative and emerging technologies affecting the derivatives and related financial markets; advancing efforts on existing consultations by discussing central counterparty resolution and recovery, margin and collateral guidelines, and technology and operations; new topics such as discussions on block implementation rules, capacity and concentration in the futures commission merchant market, Treasury market reform, and post-trade risk reduction; and finally, hearing the development of subcommittee consultations.[1]

I continue to appreciate Commissioner Johnson and the MRAC’s recognition and support of the Global Markets Advisory Committee’s (GMAC) work.  As I previously announced,[2] our upcoming July 17th meeting will address topics related to U.S. Treasury market reforms—continuing the GMAC’s work that began in 2021—swap block thresholds, and tokenization of assets.  I appreciate that the MRAC has looked to the GMAC’s initiatives over the past year, including the GMAC’s first meeting in February[3] and published 2023-2025 work program for consultation[4], and seeks to build on the GMAC’s work, including by briefly previewing these topics for the GMAC’s in-depth consideration at the NYSE next week.

Because the GMAC is focused on ensuring that there is a level playing field for global businesses and global markets, I encourage the MRAC to leverage the resources of its members and focus on pressing issues relating to risks in our markets, given the shock and turmoil of recent market stresses. It is critically important that the risks in our markets do not go unexamined by the Commission and its advisory committees.

I appreciate the MRAC’s foundation established by then-Commissioner Behnam when he sponsored the MRAC.  Indeed, to begin, we should acknowledge his MRAC’s role in the interest rate benchmark reform that we are “celebrat[ing]” today.[5]  For instance, the past iteration of the MRAC, among other things, issued a user guide for the transition of exchange-traded derivatives activity to SOFR.[6]  It is also timely, given that the Commission has just deemed approved a made-available-to-trade (MAT) determination submitted by TW SEF for certain USD SOFR and GBP SONIA swaps.[7]  I look forward to hearing updates on LIBOR transition—this is a tremendous moment in history for our markets, and a once-in-a-lifetime event given that the origins of LIBOR date back over 50 years to 1969.[8]

I reiterate that it is important for the CFTC to have expert advice from market participants and the public, and that your efforts help the Commission understand the issues from the perspective of those directly affected as we consider the most effective and efficient ways to mitigate and manage risk.[9]  I thank you again for your service and time, and look forward to the discussion.


[1] See Commissioner Kristin N. Johnson Announces Agenda for the July 10 Market Risk Advisory Committee (June 29, 2023), https://www.cftc.gov/PressRoom/PressReleases/8738-23.

[2] Commissioner Pham Announces CFTC Global Markets Advisory Committee Meeting on July 17 (June 26, 2023), https://www.cftc.gov/PressRoom/PressReleases/8730-23.

[4] Commissioner Pham Announces Proposed Work Program for CFTC Global Markets Advisory Committee and Seeks Input by May 30 (May 15, 2023), https://www.cftc.gov/PressRoom/PressReleases/8703-23.

[5] See id.

[6] See CFTC’s Interest Rate Benchmark Reform Subcommittee Issues User Guide for the Transition of Exchange-Traded Derivatives Activity to SOFR (Dec. 16, 2021), https://www.cftc.gov/PressRoom/PressReleases/8469-21.

[7] CFTC Press Release (July 7, 2023), CFTC Announces Trade Execution Requirement for Certain SOFR and SONIA OIS, https://www.cftc.gov/PressRoom/PressReleases/8745-23.

[8] Federal Reserve Bank of New York Staff Reports, LIBOR: Origins, Economics, Crisis, Scandal, and Reform, Staff Report No. 667 (Mar. 2014), https://www.newyorkfed.org/medialibrary/media/research/staff_reports/sr667.pdf.

[9] Opening Statement of Commissioner Caroline D. Pham before the Market Risk Advisory Committee (Mar. 8, 2023), https://www.cftc.gov/PressRoom/SpeechesTestimony/phamstatement030823.

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