The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting relief from the Aggregation Provision [Rule 43.6(h)(6)] in the final Block Trade Rule.

SIFMA AMG believes that asset managers should not be prohibited from aggregating
client orders involving large notional off-facility swaps under Rule 43.6(h)(6), if the
asset manager otherwise meets the conditions of the exception.
Accordingly, the AMG requests no-action relief or an alternative form of relief
or clarification to allow for large notional off-facility
swaps to be included in the exception contained in Rule 43.6(h)(6) or,
alternatively, to be excluded entirely.