The Over-The-Counter (OTC) Derivatives Product Committee of the Securities Industry Association (SIA) provides comments to the Commodity Futures Trading Commission on a proposal regarding requests for exemptive, no-action and interpretative letters, proposed new Rule 140.99 under the Commodity Exchange Act.  SIA shares concerns that certain ancillary elements of the CFTC’s rule proposal would, if implemented, have a chilling effect on the use of the staff relief process.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.