External Meetings: Meeting with Barclays Capital

On January 19, 2011, CFTC Staff met with members of Barclays Credit & Rates, Commodity Compliance, and Government Policy groups.  During the meeting, Barclays asked Staff several questions and had several comments related to the SEF NPRM as follows: (i) Request for quote (RFQ) systems – Barclays commented that there should be some accommodation to the requirement that RFQs go out to 5 market participants.  Especially in illiquid markets, this requirement could weaken liquidity and hurt prices.  One participant may be proper for less liquid products.  Staff requested that Barclays submit a comment letter on this topic; (ii) Swaps made available for trading – Barclays commented that the number of participants should be considered when assessing whether a swap is available for trading.  Staff requested that Barclays submit a comment letter on this topic; (iii) 15 second delay provision in Section 37.9(b)(3) – Barclays raised the concern about a third party stepping ahead of a second party with respect to the 15 second delay provision.  The delay may provide market participants with an incentive to wait for information.  Staff requested that Barclays submit a comment letter and request clarification on this topic.
XIII. SEF Registration

CFTC Staff
Richard Shilts

Riva Spear Adriance

Nancy Markowitz

Mauricio Melara

Amir Zaidi

Nadia Zakir

Swati Shah

David Kass

Jane Croessmann

Steven Seitz

Anthony Hays

Frank Fisanich

Greg Price

Aaron Miller

Mike Penick

Dominique Collins
Allison Parent (Barclays)

Sonali Das Theisen (Barclays)

Keith Bailey (Barclays)

Deirdre Dunn (Barclays)

Alex Guest (Barclays)
Barclays Capital