The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed business conduct standards for swap dealers and major swap participants, particularly relating to “Special Entities”, RIN 3038-AD25.  The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) defines “Special
Entities” to include government agencies, employee benefit plans under the Employee Retirement Income Security Act of 1974, governmental plans as defined in ERISA, endowments and municipalities.  AMG believes the proposal could result in unintended harm to Special Entities and would introduce unfair burdens and risks for investment advisers to Special Entities.

SIFMA AMG filed comments with the Securities and Exchange Commission (SEC) on August 29, 2011 in response to the SEC’s proposal regarding business conduct standards for security-based swap dealers and major security-based swap participants.