Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA AMG writes to express its concern regarding a change in the treatment of investment funds in the most recent draft Uncleared Swap Margin RTS. While the prior draft published by the ESAs on 8 March 2016 relieved investment funds from performing margin threshold calculations on a consolidated group basis (where there is sufficient insolvency remoteness), the recent European Commission draft published 28 July 2016 narrowed that relief to apply only to UCITS and AIFs managed by Authorized AIFMs.
SIFMA AMG believes that relief from consolidated margin threshold calculations should apply to all investment funds, whether organized and managed in the EU or in a third country, given that the same underlying rationale for such relief applies equally across jurisdictions.
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA and SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on their request for public comment on…
SIFMA AMG provided comments to the Federal Deposit Insurance Corporation (FDIC) on their consideration of various proposals to revise the…
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