Block Trade treatment for Package Transactions - New CFTC clarification

Prior to May 30, 2014, there was some uncertainty in the marketplace as to the applicability of the Block Trade rule to Packages. We have now been advised that for any Package to be entitled to Block Trade treatment, all MAT swap components of the Package must be above the applicable block level, as defined in Section 43.2. Such Block Trades, of course, will still be considered Required Transactions, but are not subject to the execution requirements.

Therefore, effective as of Monday, June 9, 2014, please note that if any MAT swap component of a given Package does not exceed the applicable block threshold, then the Package will be deemed "non-block" and will be subject to the execution requirements of Regulation 37.9. View the full notices here