AMG supports the 30-day postponement of Phase I implementation of the U.S. Final Margin Rules requested by the International Swaps and Derivatives Association and the Securities Industry and Financial Markets Association. The problems documented by both the ISDA-SIFMA Request and the request for postponement by the Global Foreign Exchange Division (“GFXD”) of the Global Financial Markets Association combined with AMG members’ own recent experiences raise significant concerns for all investors and investment vehicles that utilize uncleared derivatives as well as seeded investment funds that are part of Phase I. As detailed in the attached letter, asset managers’ clients are facing significant restrictions on uncleared derivatives trading in their prime brokerage accounts and some seeded investment funds may be restricted from uncleared swap markets entirely until Phase I readiness has been addressed.

See also:
GFMA FX Division Submits Comments to US Prudential Regulators and CFTC on a Request for Postponement of Margin Requirements for Uncleared Swaps for Phase 1 Covered Swap Entities

SIFMA AMG Submits Comments to Multiple Agencies on Final Margin Rules for Uncleared Swaps Transactions

SIFMA AMG Submits Supplemental Comments to Multiple Regulators Regarding Request for Relief on Final Margin Rules for Uncleared Swaps Transactions