Risk Management Requirements for Derivatives Clearing Organizations

The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed risk management requirements for derivatives clearing organizations (DCO), RIN 3038-AC98.  The AMG believes that the clearing requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) may reduce systemic risk but must be implemented in a way that encourages sound risk management and does not unnecessarily decrease liquidity in, or otherwise harm, the swap markets.  SIFMA AMG offers several suggestions including that the $50 million minimum net capital requirement to participate in a Derivatives Clearing Organization (DCO) is too low and such a low requirement may force members to transact with less creditworthy parties.  SIFMA AMG believes that $300 million would be a more suitable threshold.