The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the trade execution and related reporting requirements in the derivatives title (Title VII) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). The AMG offers its expertise and recommendation to the Commissions including the need for flexibility trading on “swap execution facility” and “security-based swap execution facility” (SEFs).