SIFMA AMG writes to express its concern regarding a change in the treatment of investment funds in the most recent draft Uncleared Swap Margin RTS. While the prior draft published by the ESAs on 8 March 2016 relieved investment funds from performing margin threshold calculations on a consolidated group basis (where there is sufficient insolvency remoteness), the recent European Commission draft published 28 July 2016 narrowed that relief to apply only to UCITS and AIFs managed by Authorized AIFMs.

SIFMA AMG believes that relief from consolidated margin threshold calculations should apply to all investment funds, whether organized and managed in the EU or in a third country, given that the same underlying rationale for such relief applies equally across jurisdictions.