Christopher Kirkpatrick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21st Street NW
Washington, DC 20581

Re: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants

Dear Secretary Kirkpatrick,

The Institute of International Bankers (“IIB”) and Securities Industry and Financial Markets Association (“SIFMA”)(together, the “Associations”)1 appreciate the opportunity to provide comments on Commodity Futures Trading Commission’s (“Commission”) proposal to amend Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants (the “Proposal”)2 under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). SIFMA supports the Commission’s proposal to add a sixth compliance phase for IM requirements for counterparties with average daily aggregate notional amounts (“AANA”) from $8 billion to $50 billion. The compliance date for counterparties with AANAs from $50 billion to $750 billion would remain as September 1, 2020.

This addition would align with the international margin framework, as recently amended by the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) 3 and the phase in schedule amendments recently proposed by U.S prudential regulators.4 Such harmonization is necessary to prevent fragmentation in the global markets while also minimizing the potential for regulatory arbitrage and competitive disparities.