SIFMA provides supplemental comments to the Board of Governors of the Federal Reserve System, the Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency, and the Commodity Futures Trading Commission (CFTC). This comment letter references suggested revisions to the covered fund definition regarding asset-backed and insurance-linked securities, asset-backed commercial paper and tender option bond transactions.

Also, see:  SIFMA’s initial request for an exclusion for ABS from the covered fund definition and related prohibitions of the Proposed Volcker Rule (February 13, 2012).