Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
Mr. David Stawick
Secretary
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581
Re: Notice of Proposed Rulemaking – Clearing Exemption for Swaps between Certain Affiliated Entities (RIN 3038-AD47)
The International Swaps and Derivatives Association, Inc. (“ISDA”)1 and the Securities Industry and Financial Markets Association (“SIFMA”)2 appreciate the opportunity to provide
the Commodity Futures Trading Commission (the “Commission”) with comments and recommendations regarding the proposed rulemaking (the “Proposed Exemption”)3 described
above.
ISDA and SIFMA are grateful for the Commission’s consideration of the views expressed in our letter, dated May 14, 2012, on the desirability of an exemption from the clearing and trading requirements for interaffiliate swaps. In the present letter, we respond to questions posed by the Commission regarding its Proposed Exemption, explain our views regarding why an interaffiliate clearing exemption is an appropriate and necessary exercise of the Commission’s exemptive authority and make certain recommendations regarding the Proposed Exemption.
Specifically, we recommend that: