The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed amendments to compliance obligations for commodity pool operators and commodity trading advisors.  The amendments could eliminate the exemption asset managers previously claimed from operating commodity pools.  SIFMA AMG believes that the proposed amendment should not be adopted because the associated costs to affected market participants is expected to be significant and far outweigh any perceived benefits. SIFMA AMG also describes how the proposed amendments would impose unnecessary, duplicative regulatory requirements on otherwise regulated entities.