Requesting Relief from External Business Conduct Requirements and Other Rules

SIFMA’s Asset Management Group (AMG) provides comments to the Commodity Futures Trading Commission (CFTC) supporting the International Swaps and Derivatives Association, Inc.’s (ISDA’s) request to defer compliance dates for external business conduct requirements and other information collection rules. SIFMA AMG also agrees with ISDA that the CFTC should provide such an extension through an interim final rule, rather than a no-action letter, to alleviate market concerns regarding the potential for private rights of action. AMG believes such concerns could chill liquidity and result in market disruptions after January 1, 2013 if relief were granted in the form of a no-action letter.