SIFMA provides comments to the Treasury Market Practices Group (TMPG) on Draft Recommended Agency Mortgage-Backed Securities and Agency Debt Securities Fails Charge Trading Practices. SIFMA supports the efforts of the TMPG to address fails in the Agency Debenture (Debt) and Agency Mortgage-Backed Securities (MBS) markets. SIFMA members share the concerns of TMPG members and the Federal Reserve Bank of New York (FRBNY) regarding elevated levels of settlement fails in MBS markets. SIFMA members agree that such fails create counterparty, market, other risks, and therefore share TMPG’s view that every effort should be made to minimize fails, including through the implementation of an effective fails charge.