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Proposed Clearing Determination Under Section 2(h) of the CEA

Issue

OTC Derivatives→

Summary

SIFMA’s Asset Management Group (AMG) provides comments to the Commodity Futures Trading Commission (CFTC) expressing concerns with regards to the clearing mandate of certain interest rate swaps and credit default swaps.

SIFMA AMG believes the clearing mandate is premature and despite intensive efforts of market participants, the volume of legal documentation required for compliance with the customer clearing rules makes it unlikely that the industry will be ready in time for the compliance dates triggered by this first clearing determination.

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Date

19

September

2012

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