Mr. David A. Stawick
Secretary of the Commission
Commodity Futures Trading Commission
Three Lafayette Center
1155 21st Street, NW.
Washington, DC 20581

Re: CFTC RIN 3038-AC97 – Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants

Dear Mr. Stawick,

The International Swaps and Derivatives Association1 (“ISDA”) and the Securities Industry and Financial Markets Association 2 (“SIFMA”) appreciate this opportunity to provide further
comments to the Commodity Futures Trading Commission (the “Commission” or “CFTC”) regarding the proposed rulemaking and request for comments (“NPR”) concerning margin
requirements for non-cleared swaps and the implementation of the related statutory provisions renacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”).

The Commission initially requested comments to its proposed rules on margin for uncleared swaps in early 2011. ISDA and SIFMA responded in a letter dated July 11, 2011 in which we
provided comments and recommendations on the Commission’s proposed margin rules.3 In light of the recently published study by the Basel Committee on Banking Supervision (“Basel”) and Board of the International Organization of Securities Commissions (“IOSCO”) on margin requirements for uncleared swaps (the “Study”) and the Commission’s additional request for
comments4, we have the additional comments set out in this letter.

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