Technical Standards for Uncleared Swaps Transactions

Published on:
August 23, 2016

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.

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

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