The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on certain aspects of proposed Regulation SBSR under the Securities Exchange Act of 1934 (Exchange Act), File No. S7-34-10.  The AMG offers its observations and recommendations for the reporting and dissemination of security-based swaps (SBS) requirements under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The AMG believes that: 1) the SBS reporting party should always be the SBS dealer or major SBS participant (MSP), whether or not it is a U.S. person; 2) the delay in public dissemination of block trade information should be uniform and should apply to all trade data, not just notional size; and 3) the threshold for “control” for purposes of reporting under Regulation SBSR should be raised from 25% ownership to no less than majority ownership.