WFE Response to the CFTC’s Request for Comment on the Direct Clearing of Derivatives by Retail Participants

The World Federation of Exchanges (WFE) welcomes the opportunity to respond to the request for comment issued by Commodity Futures Trading Commission (CFTC, or “the Commission”) on direct clearing of derivatives by retail participants at derivatives clearing organisations (DCOs) (“Retail DCOs”). The WFE strongly supports the Commission’s objectives of protecting retail market participants, and addressing the full set of intermediation, conduct, and risk management functions traditionally performed by futures commission merchants (FCMs).