Relief on Final Margin Rules for Uncleared Swaps Transactions
SIFMA’s Asset Management Group (SIFMA AMG) provides comments to Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve, Farm Credit Administration, Federal Housing Finance Agency (FHFA), and the Federal Deposit Insurance Corporation (FDIC) to supplement the January 19, 2016 request for relief from the requirement to consolidate seeded investment funds as “affiliates” for threshold calculations under the final margin rules for uncleared swaps transactions (Final Margin Rules).
SIFMA AMG’s letter raises a time-sensitive issue regarding the application of the final margin rules for uncleared swaps transactions upon investment funds initially funded with seed capital by a sponsor and consolidated on the sponsor’s or the sponsor’s group’s financial statements (seeded investment funds).
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