Sefs, shutdowns and no-action confusion

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As the October 2 start-date for the Dodd-Frank Act’s new swap execution facility (Sef) regime drew ever closer, a consensus emerged among market participants that despite a growing clamour for a delay, the Commodity Futures Trading Commission (CFTC) would push ahead with implementation. They were right. Unfortunately, due to the US government shutdown, there was hardly anyone at the CFTC on October 2 to witness it – or to answer the queries that emerged from newly approved Sefs and their clients

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