The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed risk management requirements for derivatives clearing organizations (DCO), RIN 3038-AC98.  The AMG believes that the clearing requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) may reduce systemic risk but must be implemented in a way that encourages sound risk management and does not unnecessarily decrease liquidity in, or otherwise harm, the swap markets.  SIFMA AMG offers several suggestions including that the $50 million minimum net capital requirement to participate in a Derivatives Clearing Organization (DCO) is too low and such a low requirement may force members to transact with less creditworthy parties.  SIFMA AMG believes that $300 million would be a more suitable threshold.