The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) expressing significant concerns regarding the straight-through processing, swap execution facility (SEF) implementation and relief relating to the aggregation provision in the Final Block Trade Rule.

In addition, SIFMA AMG requests an extension of certain no-action letters issued by CFTC staff relating to the implementation of the CFTC SEF final rules until at least February 1, 2014; and requests further no-action relief (through March 31, 2014) relating to the aggregation prohibition in the final trade block rule.