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SIFMA AMG on Capital, Margin, and Segregation Requirements for Security-Based Swaps Dealers and Major Security-Based Swaps Participants and Capital Requirements for Broker-Dealers

Summary

SIFMA AMG provides comments to the Securities and Exchange Commission (SEC) in regards to the reopening of the comment period for the proposed rules on capital, margin, and segregation requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and capital requirements for Broker-Dealers.

SIFMA AMG requests the SEC either extend the deadline for comments or re-propose the Proposal to allow a full comment period to provide for meaningful responses. Further, SIFMA AMG argued that upon initial review, many aspects of the Proposal continue to be inconsistent with standards already promulgated by other U.S. and international regulators.

See also: Reopening of Comment Periods for Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers – Nov. 19, 2018

PDF

Submitted To

SEC

Submitted By

SIFMA AMG

Date

19

November

2018

Excerpt

November 19, 2018

[email protected]

Brent Fields, Secretary
Securities and Exchange Commission
100 F St. NE
Washington, DC 20549-1090

Re: Capital, Margin, and Segregation Requirements for Security-Based Swaps Dealers and Major Security-Based Swaps Participants and Capital Requirements for Broker-Dealers (Release No. 34-84409; File No. S7-08-12)

Dear Sirs and Madams:

The Asset Management Group of the Securities Industry and Financial Markets Association (“AMG”) appreciates this opportunity to provide the Securities Exchange Commission (the “Commission”) with comments in response to the reopening of the comment period for the proposed rules on Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers (the “Proposal”). Given that the Commission is seeking comment on the potential economic effects of the Proposal in light of the numerous global regulatory and market developments since the original proposal in October of 2012, AMG respectfully requests the Commission either extend the deadline for comments or re-propose the above referenced rules to allow a full comment period during which market participants can provide meaningful feedback and requested supporting data.

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