The Asset Management Group (AMG) of SIFMA provides comments in response to the Notice of Proposed Rulemaking, issued on December 3, 2010 by the Commodity Futures Trading Commission (CFTC), regarding the CFTC’s proposed rules regarding protection of collateral posted by counterparties to swap dealers and major swap participants with respect to uncleared swaps.

This letter includes comments on the treatment of securities in a portfolio margining account in a commodity broker bankruptcy (RIN 3038-AD28).