Margin & Capital Requirements for Covered Swap Entities

SIFMA provides comments to the Board of Governors of the Federal Reserve (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Administration (FHFA), the Office of the Comptroller of the Currency (OCC), and the Farm Credit Administration (FCA), (Collectively the Agencies) on proposed margin and capital requirements for covered swap entities, Board Docket No. R-1415, Docket No. OCC-2011-0008, FDIC RIN 3064-AD79, FHFA RIN 2590-AA45, FCA RIN 3052-AC69. SIFMA strongly urges the Agencies, to the extent they wish to depart from the Proposed Margin Rule based on the final BCBS-IOSCO policy recommendations, to re-issue their proposal so that U.S. market participants have sufficient opportunity to comment on any material changes to the Proposed Margin Rule, consistent with the Agencies’ obligations under the Administrative Procedure Act.