SIFMA's Asset Management Group (SIFMA AMG) members represent U.S. asset management firms whose combined global assets under management exceed $34 trillion.


Accounting, including sales commission and other revenue recognition issues

CCO & Enforcement, including monthly review of current developments

Derivatives Advocacy

  • Uncleared swap margin requirements (North America, Europe, APAC)  
  • FX security conversion transactions (U.S., APAC)  
  • Capital requirements (U.S., International), including leverage ratio's treatment of derivatives, single counterparty credit limits and pension netting
  • Electronic derivatives trading, including swap execution rules and CFTC Proposed Regulation Automated Trading
  • Trade reporting, including unique product identifier issues and SEC reporting standards
  • Resolution stay protocol (U.S., Europe, APAC), including providing buy side feedback on the protocol, advocacy regarding Fed's TLAC and QFC proposals
  • SEC's use of derivatives proposal  
  • SEC's segregation standards for cleared security-based swaps  
  • Joint Audit Committee margin requirements, including clarification of JAC alert regarding margin netting requirements for different accounts of the same beneficial owner  

Derivatives Implementation

  • Client on-boarding template, including preparation of form for industry use
  • Client communication regarding EU counterparty classification requirements
  • Uncleared swap margin (U.S. and Europe), including review of ISDA CSAs, development of practices for asset managers to provide aggregate average notional amount (AANA) information to clients, client communication on material swap exposure (MSE) calculation requirements, development of best practices for initial margin threshold amount calculations
  • Collateral reuse disclosure (Europe), addressing disclosure requirements for collateral takers with rights of reuse (Article 15 of the SFTR)
  • Regulatory updates from counsel in the U.S., Canada, Europe and Asia

ERISA Advocacy, including DOL fiduciary rule, DOL's survey on retirement trends, state-run retirement plans, and quarterly calls to address new issues

ERISA implementation, including DOL fiduciary rule and ERISA-eligible securities

European regulation Advocacy

  • Derivatives (see above)  
  • Financial transaction tax  
  • Securitization issues  
  • EU securities financing transaction regulations  
  • Dealing commissions  
  • Brexit (Withdrawal of the United Kingdom from the European Union)
  • Mifid2 issues related to best execution, client disclosure, and suitability of investments  

Market Structure Advocacy

  • Treasury Department's request for information on US Treasury market structure
  • Broader discussions surrounding fixed income and equity market structure modernization


  • Derivatives, including education regarding operationalizing regulatory requirements such as clearing in Europe, industry standardization for regulatory reporting purposes (UPI, ISIN), helping firms ramp up for Security Based Swaps Reporting (SEC reporting)  
  • Collateral, including operational aspects of implementing margin for non-cleared OTC derivatives  
  • Custodian, regulatory change on custody operations and impact on asset manager. Alternative asset processing and related best practices  
  • Operational risk, addressing operational risk best practices in asset management firms, including incident management practices  
  • Pooled funds disclosure, including Global Investment Performance Standards proposed Guidance Statement on Broadly Distributed Pooled Funds  
  • Transition to T+2 settlement cycle, discussing any buy side specific operational challenges related to shortening the settlement cycle

SEC Investment management advocacy, including reporting, liquidity risk management, swing pricing, leverage, stress testing and use of derivatives/leverage rule proposals

U.S. Securities financing transactions, including addressing issues relating to maturing securities posted as collateral

Systemic risk, including advocating against entity designations and for reviews of asset management products and activities both in the United States and internationally

Tax, including advocating on provisions of OECD's BEPS project, FinCEN's FBAR amendments, tax reform and other tax-related legislation, taxation of financial products, Section 385 Proposed Regulations, proposed regulations on partnership audit regimes, and FATCA

Municipal Sercurities, including advocating on Puerto Rico legislation, bank loan disclosure & 15c2-12, market liquidity, and retail investor protection issues; and working to educate Washington about the benefits of a strong municipal market







Learn How ›

Contact AMG

Tim Cameron


Laura Martin


Lindsey Keljo

Elisa Nuottajarvi



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