Requesting Time Extension for Clearing Member Risk Management Requirements

The Asset Management Group of SIFMA (SIFMA AMG),the Futures Industry Association (FIA), Investment Company Institute (ICI) and Managed Funds Association (MFA) provide comments to the Commodity Future Trading Commission (CFTC) requesting an extension of time with respect to the obligations of account managers and futures commission merchants (FCMs) related to “bunched orders” under the provisions of

the CFTC Rule 1.73(a)(2)(v)(B).

The FIA developed, in consultation with the CFTC staff, an action plan and industry standard agreement in order to meet the rule requirements; and FCMs are beginning to distribute the document to their affected account managers. The groups believe that more time will be necessary to disseminate the documents and to promote industry-wide education regarding the requirements of this rule and the industry standard agreement.