Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA provides comments to the Financial Stability Oversight Council (FSOC) on the study regarding the implementation of the prohibitions on proprietary trading and certain relationships with hedge funds and private equity funds, Docket Number FSOC 2010-0002.
This comment letter relates solely to the portion of the Study related to hedge funds and private equity funds. SIFMA is writing a separate letter on the proprietary trading portion of the Study.
SIFMA believes that the issues arising out of the proprietary trading portion of the Volcker Rule are very different from those arising out of the funds portion. The proprietary trading provisions are based on vague definitions. In contrast, the provisions in the Volcker Rule relating to hedge funds and private equity funds do not generally suffer from excessive vagueness. Instead of lacking specificity, the key definitions in this portion of the Volcker Rule are generally overbroad.
While we do not address in this letter whether the activities prohibited by the Volcker Rule caused the financial crisis, we believe there are cogent arguments that they did not. We ask that the FSOC and regulators consider these arguments when implementing the Volcker Rule.
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA and SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on their request for public comment on…
SIFMA AMG provided comments to the Federal Deposit Insurance Corporation (FDIC) on their consideration of various proposals to revise the…
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