The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposal relating to the appropriate model for protecting collateral posted by customers as margin for cleared swap transactions, RIN 3038-AD99.  The AMG believes that CFTC rulemaking on the protection of cleared swaps is essential to achieving the purposes of Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), including the statutory provisions authorizing the CFTC to implement segregation requirements for cleared swaps customer collateral. The AMG shares its observations and concerns about the proposal.