Requesting Relief to the Aggregation Provision in Final Block Trade Rule

The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting relief from the Aggregation Provision [Rule 43.6(h)(6)] in the final Block Trade Rule.

SIFMA AMG believes that asset managers should not be prohibited from aggregating

client orders involving large notional off-facility swaps under Rule 43.6(h)(6), if the

asset manager otherwise meets the conditions of the exception.

Accordingly, the AMG requests no-action relief or an alternative form of relief

or clarification to allow for large notional off-facility

swaps to be included in the exception contained in Rule 43.6(h)(6) or,

alternatively, to be excluded entirely.