The trade associations signing this letter (the signatory associations) are writing to you to request that the European Commission recognize…
March 15, 2013
Basel Committee on Banking Supervision
Bank for International Settlements
International Organization of Securities Commissions
C/ Oquendo 12
Re: Comment Letter on the Second Consultative Document for the Margin Requirements for Non-Centrally-Cleared Derivatives
To Whom It May Concern:
The Asset Management Group (the “AMG”)1 of the Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to provide the Basel Commission on Banking Supervision (the “BCBS”) and the Board of the International Organization of Securities Commissions (“IOSCO”) (together with BCBS, “BCBS/IOSCO”) with our views on the recently released second consultative document on margin requirements for non-centrally cleared derivatives (the “Second Consultative Document”).2
1 The AMG’s members represent U.S. asset management firms whose combined assets under management exceed $20 trillion. The clients of AMG member firms include, among others, registered investment companies, endowments, state and local government pension funds, private sector Employee Retirement Income Security Act of 1974 pension funds and private funds such as hedge funds and private equity funds. In their role as asset managers, AMG member firms, on behalf of their clients, engage in transactions for hedging and risk management purposes that will be classified as “security-based swaps” and “swaps” under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).
2 Second Consultative Document Issued by the Basel Committee on Banking Supervision and the Board of the International Organization of Securities Commissions on Margin Requirements for Non Centrally-Cleared Derivatives, available at http://www.bis.org/publ/bcbs242.pdf.