SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on proposed amendments to FINRA Rule 4210, which would establish margin requirements for transactions in the To-Be-Announced (TBA) Market.

SIFMA supports FINRA’s stated aim to reduce counterparty credit risk and welcomes the opportunity to comment on the Proposed Amendments. In this comment letter, SIFMA focuses on the major impact of the Proposed Amendments, with details on the impact on FINRA members, while also addressing issues of clarity, operational feasibility and unintended consequences.