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Better Markets Issues Comment Letter on Real Time Reporting Requirements

The CFTC has proposed to increase the reporting timeline for block transactions in swap markets to 48 hours after the trade occurred, a 19,000 percent increase from the current requirements. This change would dramatically reduce transparency in critical swap markets and confer unfair advantages onto the four U.S. trading companies that already facilitate more than 87 percent of the $201 trillion notional in derivatives in the U.S. The empirical evidence clearly shows that timely reporting of these transactions would increase diversity and liquidity in the marketplace.