The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed rules for reporting of swap data: Real-Time Public Reporting of Swap Transaction Data, RIN 3038-AD08; Swap Data Recordkeeping and Reporting, RIN 3038-AD19; and Swap Data Repositories, RIN 3038-AD20.  Among their observations and recommendations relating to the proposed rules, SIFMA’s AMG notes certain aspects of the proposals including; Part 43 rules for real-time public reporting of swap transaction data; Part 45 rules on swap data recordkeeping and reporting; and Part 49 rules on swap data repositories.