June 10, 2022
Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Rules Relating to Security-Based Swap Execution and Registration and Regulation of Security-Based Swap Execution Facilities (File No. S7-14-22)
Dear Ms. Countryman:
The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”)1 appreciates the opportunity to provide the following response to the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Commission’s request for comment on the proposed rules related to security-based (“SB”) swap execution and registration and regulation of SB swap execution facilities (“SBSEFs”) (the “Proposed Rule” or “Regulation SE”).2
I. Introduction.
SIFMA AMG is generally supportive of the aspects of the Proposed Rule that would harmonize the SBSEF rules with the U.S. Commodity Futures Trading Commission (“CFTC”) swap execution facility (“SEF”) rules (set forth in Parts 37 and 40 of the CFTC’s regulations) and trading opportunities for asset managers on behalf of their clients. We believe there are many aspects of the CFTC’s swap market regulatory framework that functions well and provides a workable structure for the SB swap rule set including providing asset managers with improved liquidity, expanded competition, and pre- and post-trade price transparency.
1 SIFMA’s Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA 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. For more information, visit http://www.sifma.org/amg.
2 Rules Relating to Security-Based Swap Execution and Registration and Regulation of Security-Based Swap Execution Facilities, 87 Fed. Reg. 28872 (May 1, 2022).