The SIFMA Asset Management Group (SIFMA AMG) and the Investment Adviser Association (IAA) submitted a follow-up letter regarding its request for a transitional period for variation margin implementation. The letter provides additional information in support of AMG’s December 16, 2016 letter requesting six-month transitional relief from the March 1 variation margin requirements and additional transitional relief for foreign exchange (FX) clients.

This letter was submitted to:

• Board of Governors of the Federal Reserve System
• Commodity Futures Trading Commission
• European Banking Authority
• European Commission
• European Insurance and Occupational Pensions Authority
• European Securities and Markets Authority
• Farm Credit Administration
• Federal Deposit Insurance Corporation
• Federal Housing Finance Agency
• Japan Financial Services Agency
• Office of the Comptroller of the Currency
• UK Financial Conduct Authority