SIFMA/SIFMA AMG Further Implementation of Portfolio Margining and Cross-Margining of Securities and Derivatives RFC
Summary
SIFMA and SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) on the Commissions’ Joint Request for Comment on Further Implementation of Portfolio Margining and Cross-Margining of Securities and Derivatives. The request seeks input on potential ways to expand portfolio and cross-margining of securities, derivatives, and other assets subject to the jurisdiction of either or both Commissions.
Excerpt
The Securities Industry and Financial Markets Association 1 and its Asset Management Group 2 (collectively, “SIFMA”) appreciate the opportunity to provide comments to the U.S. Commodity Futures Trading Commission (the “CFTC”) and the U.S. Securities and Exchange Commission (the “SEC” and together with the CFTC, the “Commissions”) in response to the Commissions’ Joint Request for Comment on Further Implementation of Portfolio Margining and Cross-Margining of Securities and Derivatives (the “Request for Comment”). The Request for Comment seeks input on potential ways to expand portfolio and cross-margining of securities, derivatives and other assets that are subject to the jurisdiction of either or both Commissions. 3
As the Commissions recognize, financial markets are becoming increasingly interconnected, and market participants frequently manage portfolios or implement hedging and other trading strategies that use economically related positions across cash securities, listed and over-the-counter options, futures, swaps, and security-based swaps (“SBS”). More recently, they also trade other non-securities financial assets, such as digital commodities. These positions may reference the same underlying asset, address the same economic exposure, or otherwise serve related risk-management purposes. Nevertheless, current regulatory requirements often require such positions to be maintained in separate accounts and margined under different methodologies, even where the positions present offsetting exposures. As the Request for Comment observes, this regulatory structure may produce capital inefficiencies or increased liquidity demands “without necessarily enhancing market stability.” In some circumstances, preventing recognition of economically offsetting positions may itself increase market and systemic risk by generating duplicative liquidity demands, additional settlement flows, and incentives to unwind otherwise risk-reducing positions during periods of market stress.
- SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
- SIFMA’s Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms that manage more than 50% of global AUM. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.
- See 91 FR 39579 (June 30, 2026).