The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting an extension of time to comply with the CFTC’s recent amendments to CFTC Rules 4.5 and 4.13 and to clarify implementation issues raised by these rules.  Specifically, the AMG asks that Commodity Pool Operators (CPOs) of private pools have until at least December 31, 2012 to comply with the Rule 4.13 amendments.  In addition, funds that use swaps should be provided a minimum of 10 months after the effective date of the final swap rules (i.e. definition of “swap” rule) in order to assess their CPO status in light of new definitions, margin requirements, and to modify their operations as necessary for compliance.