The Commission refuses to reduce the ban, as requested by the ICAP TP, and adopts, as proposed, point 37.9 (d) for swaps to be approved. The Commission continues to believe that there is no need to abandon names after trading when a swap is made on an SEF and a DCO is submitted for compensation in accordance with Gfb0 requirements. A narrowing of the prohibition on the use of only trading contracts that must be authorized under Section 2 H) (1) of the Act would unduly limit its scope and interfere with the legal and regulatory objectives underlying the prohibition. Removing a swap is an essential concept that affects trading prices and workflows, and it`s something an SEF can determine at the time of execution.  However, to the extent that the current FSS systems do not specify whether a swap should be approved, the Commission notes that the SEF must make the necessary adjustments to its systems and procedures to ensure that it can determine whether a swap must be approved before allowing post-trade names.  The Commission recognises that some EFs may need time to make such adjustments and the Commission has launched page 44699, which is why it indicates a later date for discretionary swaps, as described below. Finally, in response to the comments of Citadel and FIA PTG, the Commission states that the “planned release” must be interpreted in the sense that swaps must be presented at the same time as the execution of the compensation declaration. Therefore, if a swap begins as an unexplained transaction and counterparties later voluntarily place it in clearing, the swap would not be considered “intent to be approved” and therefore would not be subject to the prohibition of the addition of names.  On November 30, 2018, the Commission published a request in the Federal Register for advice on the practice of assigning surnames to SEFs (RFC 2018).  As described in RFC 2018, some EFS facilitate post-trading reductions by revealing, directly or indirectly, the identities of swap counterparties after a trade has been settled anonymously.