Aggregation of Positions

The Asset Management Group of SIFMA (SIFMA AMG) and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) requesting that the CFTC extend the comment period for the Aggregation Notice of Proposed Rulemaking (Aggregation NOPR, RIN 3038–AD82) to align it with the end of the comment period for the Position Limits for Derivatives Notice of Proposed Rulemaking (Position Limits NOPR).

As the two Proposed Rules are inextricably linked, we believe it is essential to have sufficient time to review and comment on them together.

Moreover, in order to fully ascertain the impact on their businesses, including compliance costs, related to the proposed rulemakings, our members must apply the Proposed Rules in conjunction with one another. To fully comprehend the impact of the Aggregation NOPR, our members must first fully review, understand and apply the Position Limits NOPR. Both Rule Proposals are complex and understanding their combined impact will require more time beyond January 14, 2014.

In order to have adequate time to review, consider, and comment upon these two Rule Proposals together, we are requesting an extension of the comment period for the Aggregation NOPR to align it with the end of the comment period for the Position Limits NOPR.