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.