Modernizing Delivery Requirements Under the Federal Securities Laws (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) requesting that the SEC take necessary steps…
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC’s proposal Position Limits on Derivatives, RIN 3038-AD11.
SIFMA AMG recognizes that regulatory action may be appropriate under certain circumstances in order to achieve the goals set forth in the Commodity Exchange Act (CEA) for setting position limits, namely to prevent market manipulation, protect against excessive speculation, ensure sufficient market liquidity for bona fide hedgers, and deter disruption to price discovery, including preventing price discovery from moving to foreign boards of trade (FBOTs), but continues to question whether position limits would achieve these goals, particularly as proposed under the 2013 NPRM.
SIFMA AMG believes that under the CEA, the CFTC must find that speculative position limits are “necessary” and “appropriate” and balance several countervailing statutory factors on a contract-by-contract basis before promulgating position limits rules. The CFTC has not met these statutory requirements in promulgating the 2013 NPRM. The group requests that the CFTC withdraw this proposal to make the needed findings.
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) requesting that the SEC take necessary steps…
SIFMA provided comments to the U.S Securities and Exchange Commission (SEC) to confirm their discussion on July 29, 2025 with…
SIFMA provided additional comments to the U.S. Department of the Treasury (DOT) on the 2024 Final Regulations and 2024 Proposed…