Margin and Capital Requirements for Covered Swap Entities

Published on:
November 24, 2014
Submitted to:
OCC, Federal Reserve, FDIC, FHFA, Farm Credit Administration and CFTC
Submitted by:
SIFMA

Summary

SIFMA provided comments to multiple agencies, including the Commodity Futures Trading Commission (CFTC) and U.S. prudential regulators, regarding their proposals on margin requirements for uncleared swaps.

Excerpt

November 24, 2014

Legislative and Regulatory Activities Division

Office of the Comptroller of the Currency

400 7th Street, SW

Suite 3E-218, Mail Stop 9W-11

Washington, DC 20219

Robert deV. Frierson, Secretary

Board of Governors of the Federal Reserve System

20th Street and Constitution Avenue, N.W.

Washington, DC 20551

Robert E. Feldman, Executive Secretary

Attention: Comments

Federal Deposit Insurance Corporation

550 17th Street, N.W.

Washington, DC 20429

Alfred M. Pollard, General Counsel

Attention: Comments/RIN 2590-AA45

Federal Housing Finance Agency

Constitution Center (OGC Eighth Floor)

400 7th Street, SW

Washington, DC 20024

Barry F. Mardock, Deputy Director

Office of Regulatory Policy

Farm Credit Administration

1501 Farm Credit Drive

McLean, VA 22102

Christopher Kirkpatrick, Secretary

Commodity Futures Trading Commission

1155 21st Street, N.W.

Washington, DC 20581

Re: Margin and Capital Requirements for Covered Swap Entities, Docket ID OCC-2011-0008/RIN 1557-AD43, Docket No. R-1415/RIN 7100 AD74, RIN 3064-AE21, RIN 2590-AA45, RIN 3052-AC69;1

Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants, RIN 3038-AC97.2

Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”)3 welcomes this opportunity to comment on the captioned rule proposals (the “Proposed Rules”) published by the

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1 79 Fed. Reg. 57348 (Sept. 24, 2014) (the “Bank Proposal”).

2 79 Fed. Reg. 59898 (Oct. 3, 2014) (the “CFTC Proposal”).

3 SIFMA brings together the shared interests of hundreds of securities firms, banks and asset managers. SIFMA’s mission is to support a strong financial industry, investor opportunity, capital formation, job creation and economic growth, while building trust and confidence in the financial markets. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association. For more information, visit www.sifma.org.

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