IFR and Proposed Rules Extending Phase 5 and 6 Compliance Dates for Regulatory Initial Margin

Published on:
August 5, 2020
Submitted to:
CFTC
Submitted by:
SIFMA, SIFMA AMG, ISDA, GFMA, GFXD, MFA, IAA, IIB, ICI, CCMC, ACLI

Summary

SIFMA and joint trades provided comments to the Commodity Futures Trading Commission (CFTC) on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants.

Excerpt

August 5, 2020

Christopher Kirkpatrick

Secretary of the Commission

Commodity Futures Trading Commission

Three Lafayette Center

1155 21st Street NW

Washington, DC 20581

Re: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants: RIN 3038–AF02 and RIN 3038-AF03

Dear Secretary Kirkpatrick,

The International Swaps and Derivatives Association (ISDA), the Securities Industry and Financial Markets Association (SIFMA), SIFMA Asset Management Group (SIFMA AMG), the Global Financial Markets Association (GFMA), the Global Foreign Exchange Division (GFXD) of GFMA, Managed Funds Association (MFA), Investment Adviser Association (IAA), the Institute of International Bankers (IIB), the Investment Company Institute (ICI), the U.S. Chamber’s Center for Capital Markets Competitiveness (CCMC) and the American Council of Life Insurers (ACLI) (together, the Associations (1) would like to express our appreciation for the swift and decisive actions taken by the Commodity Futures Trading Commission (the “CFTC”) to provide timely and valuable regulatory relief to market participants in response to the global COVID-19 pandemic. In particular, we would like to express our gratitude for the CFTC’s support of the statement (2) and revised version of the Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives (Final Framework) (3) issued on April 3, 2020 by the Basel Committee on Bank Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) in response to the letter submitted on March 25, 2020 (4) by the Associations and other global financial market associations requesting a delay of the final phase-in periods for regulatory initial margin.

1 See Appendix for descriptions of the Associations.

2 https://www.iosco.org/news/pdf/IOSCONEWS560.pdf

3 BCBS-IOSCO Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives (April 2020), available at: https://www.iosco.org/library/pubdocs/pdf/IOSCOPD651.pdf.

4 https://www.isda.org/a/sM7TE/IMPhase5-6COVID-19Letter.pdf

Continue Reading

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.