SIFMA and joint trades provided comments to the Office of the Comptroller of the Currency, Federal Housing Finance Agency, Federal…
August 5, 2020
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21st Street NW
Washington, DC 20581
Re: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants: RIN 3038–AF02 and RIN 3038-AF03
Dear Secretary Kirkpatrick,
The International Swaps and Derivatives Association (ISDA), the Securities Industry and Financial Markets Association (SIFMA), SIFMA Asset Management Group (SIFMA AMG), the Global Financial Markets Association (GFMA), the Global Foreign Exchange Division (GFXD) of GFMA, Managed Funds Association (MFA), Investment Adviser Association (IAA), the Institute of International Bankers (IIB), the Investment Company Institute (ICI), the U.S. Chamber’s Center for Capital Markets Competitiveness (CCMC) and the American Council of Life Insurers (ACLI) (together, the Associations (1) would like to express our appreciation for the swift and decisive actions taken by the Commodity Futures Trading Commission (the “CFTC”) to provide timely and valuable regulatory relief to market participants in response to the global COVID-19 pandemic. In particular, we would like to express our gratitude for the CFTC’s support of the statement (2) and revised version of the Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives (Final Framework) (3) issued on April 3, 2020 by the Basel Committee on Bank Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) in response to the letter submitted on March 25, 2020 (4) by the Associations and other global financial market associations requesting a delay of the final phase-in periods for regulatory initial margin.
1 See Appendix for descriptions of the Associations.
3 BCBS-IOSCO Final Framework on Margin Requirements for Non-Centrally Cleared Derivatives (April 2020), available at: https://www.iosco.org/library/pubdocs/pdf/IOSCOPD651.pdf.