Joint Trades on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
SIFMA, ISDA, and GXFD sent comments to the CFTC on the Notices of Proposed Rulemaking in respect of the Margin…
Melissa Jurgens, Secretary
Commodity Futures Trading Commission
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Elizabeth M. Murphy, Secretary
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Robert E. Feldman, Executive Secretary
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Attention: Comments/RIN 2590-AA45
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Re: Margin Requirements for Non-Centrally Cleared Swaps and SecurityBased Swaps
Ladies and Gentlemen:
The Securities Industry and Financial Markets Association (“SIFMA”) is writing with respect to the proposed margin requirements for non-centrally cleared swaps and security- based swaps (the “U.S. Margin Proposals”) published by the Prudential Regulators, the Commodity Futures Trading Commission (the “CFTC”) and the Securities and Exchange Commission (the “SEC,” and, together with the CFTC and the Prudential Regulators, the “Agencies”) pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”).2
We understand that the Agencies are considering modifications to the U.S. Margin Proposals in order to harmonize U.S. margin requirements for non-centrally cleared swaps and security-based swaps with the final policy framework agreed by the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) for margin requirements for non-centrally cleared derivatives (the “BCBS-IOSCO Framework”).3
In this letter, we summarize and discuss, for the consideration of the Agencies in their respective U.S. Margin re-Proposals, certain key issues that are either raised by national implementation of the BCBS-IOSCO Framework or unresolved by the BCBS-IOSCO Framework. SIFMA believes that effective and consistent resolution of these issues across U.S.
and international regulators is necessary to achieve the objectives of the BCBS-IOSCO Framework.4 This letter is intended to complement the letter submitted to the Agencies by the
International Swaps and Derivatives Association (“ISDA”) on February 5, 2014.