The leadership of AMG is comprised primarily of Chief Operating Officers and other senior executives at asset management firms. The members of the Group meet regularly to advance their advocacy efforts, develop enhancements to market practices, and work with trading partners in order to increase efficiency and reduce risks and costs.
The AMG works closely with its operations oriented affiliate, The Asset Managers Forum (AMF), in its investment operations-focused initiatives.
Asset Management Group Committees
The Asset Management Group (AMG) Steering Committee directs the prioritization of AMG initiatives. The Committee addresses more general regulatory issues, such as Non-Bank Systemically Important Financial Institutions (SIFIs), debt-ceiling implications and the JOBS Act.
- Asset Management Accounting Committee
Objective: Address emerging issues and exposure drafts from the FASB and IFRS. Representative topics covered include: Consolidation - Agent vs. Principal, Investment Companies, Investment Property Entities, and Revenue Recognition.
Objective: Address issues impacting the fixed-income marketplace, including market structure for the trading of bonds, and issues related to municipal bonds, loan convenants and creditors' rights.
Objective: Work with industry stakeholders and key regulators to ensure Title VII of the Dodd-Frank Act is implemented in a manner that promotes transparency, enhances liquidity, and increases customer protection, without unduly increasing costs. The Derivatives Committee also assists with the development of market structure and tools to help asset managers comply with derivatives rules. Examples of issues addressed by this committee include: advocacy for workable Commodity Pool Operator (CPO) rules, less onerous margin requirements; enhanced protections for customer collateral; flexible means for executing swaps transactions on Swap Execution Facilities (SEFs); and defining thresholds for swap market participants, among others. Frequently address, and work with, key regulators on these issues.
Objective: Address issues relating to the distribution of funds and accounts. Issues that may be addressed by this committee include: the SEC's examination of 12b-1 fees; a fiduciary standard for broker-dealers; advertising; communications with the public; complex products; financial intermediary oversight; and ERISA/DOL issues (including the definition of fiduciary). This committee may conduct meetings in Roundtable settings.
- Equity Market Structure Committee
Objective: Formulate industry policy positions on equity market structure-related issues, such as high frequency trading, liquidity issues, circuit breaker/"limit-up, limit-down", and access and liquidity fees.
Objective: Address potential changes to the oversight and regulation of money market funds, from the SEC and the FSOC. Further engage the appropriate regulators in any proposed reforms.
Objective: Work with industry stakeholders and key regulators to ensure the development of a robust securitization market. Representative issues addressed by this committee include: tackling the attempted use of Eminent Domain as a solution for municipalities with a significant number of under of underwater mortgages; assisting the NY Fed-sponsored Treasury Market Practices Group with their Fails Charge and TBA Margining initiatives; addressing housing finance reform (e.g., the FHFA Single Platform Initiative; GSEs; QM/QRM); and minimizing the impact of CPO rules on securitization vehicles.
Objective: Address sweeping tax-related reforms. Areas of interest include: the Foreign Account Tax Compliance Act (FATCA); the Camp Derivatives Tax Proposals, the EU Financial Transaction Tax; and amending and extending the compliance date for the report of Financial Bank and Financial Accounts (FBAR).
Objective: Address the regulators' proposed Volcker Rule, including the proposed limits on proprietary trading and sponsoring certain private funds. Advocate for regulators to clearly define "private equity fund" and "hedge fund" in a manner that does not improperly sweep in entities, which would restrict or prohibit normal business practices (e.g., ensure the customer relationship is defined flexibly enough so that it does not disrupt the current practice for sales of hedge funds to prospective investors by using the SEC's private placement substantive pre-existing relationship (SPR) standard). Seek to limit the Volcker's Rule prohibition on proprietary trading so it does not impair liquidity by adopting too narrow of a definition of market making or hedging.
SIFMA's Dodd-Frank Rulemaking Committees
Asset Managers Forum Committees
Objective: Provide education to the buy-side for key issues, applications and best practices in the collateral management space. Discuss and find solutions for current challenges for both bi-lateral and cleared transactions; discuss best practices on common buy-side issues; determine critical performance indicators to enable firms to benchmark their performance; and monitor industry changes to evaluate how they impact the buy-side community.
Objective: Mobilize custodians who are dedicated to working jointly alongside asset managers, brokers and government entities in order to address industry and regulatory challenges.
- Derivatives Operations Committee
Objective: Focus on key operational challenges related to swaps and over-the-counter derivatives, including introduction of a central clearing counterparty or swap execution facility.
- Operational Risk Committee
Objective: Discuss and recommend best practices for defining, managing and monitoring operational risk.
- STP/Trade Processing Committee
Objective: Provide an organizational structure to focus on a wide variety of trade processing challenges that asset managers face. The Committee's initial focus has been on MBS fail charge processing and reporting. Other important issues include shortening the settlement cycle and requiring a match to settle trades at DTCC. The STP Committee coordinates several working groups, including: the Improving STP Working Group; the Tri-Party Repo Working Group; and the TMPG Working Group.
Objective: Analyze and provide response to recommendations of the New York Fed Task Force on Tri-Party Repo Infrastructure from the asset management industry perspective. Offer guidance for asset managers on operational implementation of these recommendations, and work together with industry constituents to develop operational solutions. The Committee works in conjunction with the Rates Division's Government Operations Committee.