The Ad Hoc Portfolio Margining Committee, the Derivatives Product Committee and the Options Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on the proposals to amend the portfolio pilot program, File No. SR-NYSE-2006-3, and File No. SR-CBOE-2006-14.  SIA believes the proposals can be strengthened. For example, portfolio margining accounts should include as eligible products nonequities securities, interest rate derivatives, collateralized debt obligations (CDOs) and other similar non-equity related products as well as foreign currency derivatives.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.