SIFMA provides comment to the Commodity Futures Trading Commission (CFTC) on the Protection of Cleared Swaps Customers Before and After Commodity Broker Bankruptcies (the ANPR), RIN 3038-AD99; 17 CFR Part 190.  The ANPR outlines four models for the segregation of collateral posted by customers to futures commission merchants (FCMs) in support of swaps cleared through a derivatives clearing organization (DCO).  The models are being considered by the CFTC as a way to implement Commodity Exchange Act (CEA) Section 4d(f)(2), which was added by Section 724 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  While supporting the goals of CEA Section 4d(f)(2), the protection of customers and the minimization of costs; SIFMA notes that the expansion of portfolio margining is also a goal of the Dodd-Frank Act, and urges the CFTC not to implement Section 4d(f)(2) in such a way that would hinder the expansion of portfolio margining goal.