SIFMA Asset Management Group (SIFMA AMG), Investment Adviser Association, the Investment Company Institute (ICI), and the Managed Funds Association (MFA), and the the Alternative Investment Management Association submitted revised comments to the Commodity Futures Trading Commission (CFTC) requesting the Division of Swap Dealer and Intermediary Oversight (DSIO) of the CFTC grant relief that would permit a fund to net uncleared swaps for purposes of the net notional test provided that: (1) the termination dates of the offsetting swaps are the same, (2) the reference asset or rate for the offsetting swaps is the same, and (3) the swaps to be netted are either (A) with the same counterparty or (B) with different counterparties, but the offsetting swaps are both outstanding only for seven business days or fewer.

Related Material 

Original Joint Comments – SIFMA AMG and other Associations Submit Comments to the CFTC on the Netting of Swaps (January 25, 2013)