Capital, Margin & Segregation Requirements for SBS Dealers & MSBS Participants & Capital Requirements for BDs


SIFMA provides comments to the SEC on Capital, Margin and Segregation Requirements for Security-Based Swap Dealers (SBSDs) and Major Security-Based Swap (MSBS) Participants and Capital Requirements for Broker-Dealers (BDs), Release No. 34-68071; File No. S7-08-12.  SIFMA recognizes that, in implementing capital, margin and segregation requirements for nonbank SBSDs, the Commission has largely drawn from its existing broker-dealer financial responsibility rules and sought to adapt those rules for SBSDs. Nevertheless, we are concerned that this approach, without further modification, does not adequately address or conform to the statutory principles.