Comment on CFTC-2026-1321, CFTC-2026-1321-0001, SOFR Academy, Inc.

Summary: SOFR Academy, Inc. supports the request for information by advocating for specific interpretive guidance and potential no-action relief from the CFTC. They argue that swaps referencing transaction-based benchmark credit-spread indices (like AXI or FXI) should be classified as interest-rate swaps to reduce operational uncertainty and facilitate the development of lending and hedging infrastructure.