October 20, 2017

Brent J. Fields, Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549–1090

Re: (1) Letter dated September 22, 2017 to Honorable Jay Clayton re DTCC Data Repository, LLC’s (“DDR”) Request for Exemptive or Interpretive Relief from Certain Provisions of Section 13(n)(1) of the Securities Exchange Act of 1934 and the Rules and Regulations Thereunder (the “DDR Letter”) related to the Amended Application of DDR for Registration as a Security Based Swap Data Repository (File No. SBSDR–2016–02) (the “DDR Amended Application”).1

(2) Letter dated September 26, 2017 to Honorable Jay Clayton re ICE Trade Vault, LLC’s (“ICE Trade Vault”) Request for Exemptive or Interpretive Relief from Certain Provision of Section 13(n)(1) of the Securities Exchange Act of 1934 and the Rules and Regulations Thereunder (the “ICE Trade Vault Letter”) related to the Amended Application of ICE Trade Vault for Registration as a Security-Based Swap Data Repository (File No. SBSDR2017-01) (the “ICE Trade Vault Amended Application”). 2

Dear Mr. Fields:

The Asset Management Group of the Securities Industry and Financial Markets Association (“AMG”)3 writes in response to the above-listed recent requests for relief filed in relation to the amended applications of DDR and ICE Trade Vault to register as security-based swap data repositories (‘‘SDR’’) for security-based swaps (‘‘SBS’’). The DDR Letter requests, among other things, that the Securities and Exchange Commission (the “Commission”) confirm that DDR’s Amended Application complies with its obligations regarding accuracy and completeness for certain policies involving non-reporting counterparties.4 The ICE Trade Vault Letter, among other things, requests that the Commission require non-reporting SBS counterparties to onboard as full users in order to submit any information to the SDR. 5 For the reasons stated below, AMG supports DDR’s request (subject to AMG’s prior comments, 6 discussed below) and objects to ICE Trade Vault’s request to mandate onboarding of non-reporting counterparties.

Throughout the evolution of Regulation SBSR—Reporting and Dissemination of SecurityBased Swap Information (“Regulation SBSR”)7 and the SBS SDR registration process, AMG has consistently demonstrated that imposing full user on-boarding requirements upon non-reporting counterparties is unnecessary, counterproductive and unduly burdensome. AMG’s members execute SBS transactions as executing agents on behalf of pension funds, registered funds (e.g., mutual funds, UCITS) and institutional clients who do not have the responsibility to report transactions to the SDR. Although AMG supports SBS reporting and believes that both ICE Trade Vault and DDR are well-equipped to serve as SBS DRs, AMG believes that non reporting parties should be permitted to fulfill their limited obligations without having to fully on-board as users of the SDR. The non-reporting counterparty plays a limited and passive role in SBS reporting. The non-reporting party does not control where the reporting party reports the trades and only interacts with the SBS DR to correct errors pursuant to Rule 905 and, to the extent applicable under Rule 906, identify missing UIC information and parent/affiliate information. Given the existing, robust trade confirmation process and obligations imposed squarely upon the reporting side, the statutory aim of accurate reporting is satisfied by lesser means than onboarding of the non-reporting counterparty that allow the non-reporting counterparty to provide any minimal information that may need to be submitted.

To impose full SDR user requirements upon the non-reporting counterparty would cause AMG members’ clients to incur material costs charged by the SDRs and to agree to a number of SDR obligations and indemnities, none of which is justified by the limited role of the non-reporting counterparty. 8 It would also require unnecessary technology builds and testing for full user interfacing with the SDRs.

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1 The DDR Letter is available at: https://www.sec.gov/comments/sbsdr-2016-02/sbsdr201602-2590214-161092.pdf.

2 The ICE Trade Vault Letter is available at: https://www.sec.gov/comments/sbsdr-2017-01/sbsdr201701-2597993-161125.pdf.

3 AMG brings the asset management community together to provide views on policy matters and to create industry best practices. AMG’s members represent U.S. and multinational asset management firms whose combined global assets under management exceed $39 trillion. The clients of AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

4 DDR Letter at 2-5.

5 ICE Trade Vault Letter at 2-3.

6 See SIFMA AMG Comment Letter dated August 30, 2017 re DDR Amended Application, available at: https://www.sifma.org/resources/submissions/sifma-amg-comments-on-amended application-of-dtcc-datarepository/

7 17 C.F.R. § 242.900 et seq.

8 See SIFMA AMG’s May 31, 2016 Comment Letter re ICE Trade Vault’s Application for Registration as an SDR, available at: https://www.sifma.org/wp-content/uploads/2017/05/sifma amg-submits-comments-tosec-on-the-application-for-registration-of-ice-trade-vault-llc-as-a-security-based-swap-data-repository.pdf; SIFMA AMG’s August 5, 2016 Comment Letter re DDR’s Application for Registration as an SDR, available at: https://www.sifma.org/wp-content/uploads/2016/08/SIFMA-AMG-Submits-Comments-to-the-SECon-Security-Based-Swap Data-Repositories.pdf.