The Application for Registration of ICE Trade Vault LLC as a Security-Based Swap Data Repository
SIFMA AMG provides comment to the Securities and Exchange Commission (SEC) regarding the Application for Registration of ICE Trade Vault LLC as a Security-Based Swap Data Repository. Security-based swaps are important investment and risk management tools for asset managers, whose clients include registered investment companies, endowments, public and private pension funds, unit investment trusts and private funds. While AMG continues to support SBS reporting and believes that ICE is well-equipped to serve the role of SBS DR, AMG believes that ICE should revise its on-boarding requirements to provide a mechanism for non-reporting parties, such as asset managers’ clients, to serve their limited role without fully on-boarding and restrict requirements to those set forth in Commission Regulation. Further, AMG believes that ICE should clarify that certain unique identification codes and parent/affiliate fields are not required for SBS transactions executed by an asset manager as execution agent. Finally, AMG asks that the Commission provide clarity on the schedule for SBS reporting compliance and, prior to the compliance date, impose a cap on the reporting of notional amounts for block trades so that the market can transition without disruptions.
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