The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposed rule relating to customer clearing documentation and timing of acceptance for clearing, RIN 3038-AD51.  This proposal was issued by the CFTC with the goal of promoting open access to clearing for market participants.  It addresses the documentation between a customer and a futures commission merchant (FCM) and the timing of acceptance/rejection of trades for clearing by derivatives clearing organizations and its members.  SIFMA AMG supports the CFTC’s intentions and reiterates that customers should have the opportunity to execute with a broad range of counterparties and any documentation framework should not allow limits on the sizes of trades to be set by an FCM.  In addition, the SIFMA AMG agrees with the CFTC that there should be non-disclosure of the identity of a client’s executing counterparty to the FCM to prevent unnecessary involvement by the FCM in any execution decisions.