March 15, 2013

Secretariat of the Basel Committee on Banking Supervision
Bank for International Settlements
Centralbahnplatz 2
CH-4002 Basel
Switzerland
Sent by email to: [email protected]

Secretariat of the International Organization of Securities Commissions
C/ Oquendo 12
28006 Madrid
Spain
Sent by email to: [email protected]

Re: Second Consultative Document: Margin Requirements for Non-Centrally-Cleared Derivatives (February 2013)

Ladies and Gentlemen:
The Securities Industry and Financial Markets Association (“SIFMA”)1  appreciates the opportunity to comment on the captioned second consultative document (the “Second Consultation”) issued by the Working Group on Margining Requirements (the “WGMR”) of the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”). The Second Consultation follows the
original consultative document on margin requirements for non-centrally-cleared derivatives released in July 2012 (the “Original Consultation” and, together with the Second Consultation, the “Consultations”). SIFMA commented on the Original Consultation in a letter dated September 28, 2012 (the “September Comment Letter”). SIFMA welcomes the continued attention of the BCBS and IOSCO to international harmonization of margin requirements for non-centrally-cleared derivatives.

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1 SIFMA brings together the shared interests of hundreds of securities firms, banks and asset managers.
SIFMA’s mission is to support a strong financial industry, investor opportunity, capital formation, job creation and
economic growth, while building trust and confidence in the financial markets. SIFMA, with offices in New York
and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association. For more
information, visit www.sifma.org