BPI Submits Comment Letter to CFTC on Proposal to Prohibit ‘Post-Trade Name Give-Ups’ for Anonymous Swaps

On March 10, BPI submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its recent proposal to ban post-trade name give-up (PTNGU) for swaps executed anonymously in a swap execution facility that are intended to be cleared. BPI’s letter opposes the CFTC’s proposal, noting that PTNGU plays an integral role in a well-functioning swap market. The letter also outlines a number of potential consequences of the proposed ban, including not only a disruption to the swap market but also dealers reassessing the extent of their involvement in the swaps market, which could result in wider spreads and less liquidity. Finally, the letter encourages the CFTC to conduct a more comprehensive cost-benefit analysis of PTNGU before finalizing the rule and to consider a more incremental approach to addressing PTNGU.