Office of the Comptroller of the Currency
Federal Deposit Insurance Corporation
Farm Credit Administration
Board of Governors of the Federal Reserve
Federal Housing Finance Agency

Re: Margin and Capital Requirements for Covered Swap Entities – Office of the Comptroller of the Currency (RIN: 1557-AE69); Board of Governors of the Federal Reserve (RIN: 7100-AF62); Federal Deposit Insurance Corporation (RIN: 3064-AF08); Farm Credit Administration (RIN: 3052-AD38); Federal Housing Financing Agency(RIN: 2590-AB03)1

Dear Sirs and Madams:

The Asset Management Group of the Securities Industry and Financial Markets Association (“AMG” or “SIFMA AMG”) and the American Council of Life Insurers (“ACLI” together, the “Associations”) 2 appreciate the opportunity to provide comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, Farm Credit Administration, and Federal Housing Financing Agency (the “Prudential Regulators”) on the Proposal. The Associations are supportive of the amendments in the Proposal that would incorporate the recent Basel Committee on Banking Supervision and the International Organization of Securities Commissions’ (“BCBS-IOSCO”) statements on documentation and extending the implementation of the remaining phases of the initial margin requirements for non-centrally cleared derivatives (“UMRs”). The Associations are also supportive of the proposed rules on relief for IBORs transitions and portfolio compression exercises. While the changes in the Proposal serve to codify helpful relief for the implementation of the UMR Rules, these changes alone will not remediate the substantial challenges faced by asset managers, their clients, and life insurers as they implement the UMR during the final phases of the implementation schedule, and therefore, we believe further changes are necessary to account for the scoping and implementation challenges faced by asset managers their clients, and life insurers.

The Associations appreciate the commitment of the Prudential Regulators to ensure a robust and workable uncleared margin framework. The Prudential Regulators’ current review of the margin framework is well-timed given the challenges that have arisen as asset managers, their clients, and life insurers have begun preparations for the final stages of the implementation schedule. In response to these challenges, both AMG and ACLI recently submitted letters to global regulators on the remaining stages of the initial margin phase-in, and have continued to provide feedback to the Prudential Regulators. 3 The Associations continue to have significant concerns with respect to the scoping of the UMR and implementation issues that are specific to asset managers. To solve for the various challenges posed by the UMR, in addition to the relief afforded in the Proposal, the Associations propose certain scoping and implementation solutions for which we believe will allow for a more orderly implementation of the UMR. A summary of these solutions is provided below.