SIFMA AMG Recommendations on Private Markets Regulatory Reforms
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) regarding potential regulatory reforms to enhance retail access…
Cross-product Netting Under the US Regulatory Capital Framework
Dated: April 8, 2025 Executive Summary The International Swaps and Derivatives Association, Inc. (ISDA), FIA and the Securities Industry and…
Request for Information on the Development of an AI Action Plan (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the National Science Foundation on the Office of Science and Technology Policy (OSTP)…
SIFMA Statement on the Introduction of the GROWTH Act
Washington, D.C., March 13, 2025 – SIFMA and SIFMA’s Asset Management Group (SIFMA AMG) today issued the following statement from…
SIFMA AMG Priority Issues for Consideration
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) to highlight its members’ priorities for consideration.
Notice of Filing of an Application for Registration as a Clearing Agency Under Section 17A of the Securities Exchange Act of 1934 (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Application for Registration as…
The 2025 Asset Management Derivatives Forum Debrief
A Joint Publication from FIA Research and SIFMA Insights Recently, the Futures Industry Association (FIA) and the SIFMA Asset Management…
SIFMA AMG Statement on the FDIC Withdrawal of Bank “Control” Rule Proposal
Washington, D.C., March 5, 2025 – SIFMA’s Asset Management Group (SIFMA AMG) today issued the following statement from Lindsey Keljo, Head…
Financial Stability Board Consultation Report, December 18, 2024 “Leverage in Non-bank Financial Intermediation” (SIFMA AMG)
SIFMA AMG provided comments to the Financial Stability Board (FSB) on their Consultation Report on Leverage in Non-bank Financial Intermediation…
What the New Treasury Clearing Timeline Means for Markets
In this episode of The SIFMA Podcast, SIFMA's COO, Joseph Seidel sits down with Robert Toomey, the head of our…
What’s Next for Global Derivatives Trading
In February, SIFMA AMG and FIA hosted the annual Asset Management Derivatives Forum, where we brought together market participants from…
Public Comment on Pre-Hedging Consultation Report (SIFMA AMG, ICI and ACLI)
SIFMA AMG, the American Council of Life Insurers (ACLI), and the Investment Company Institute (ICI) submitted comments to the International…
Standards for Covered Clearing Agencies for US Treasury Securities and Application of the Broker-Dealer Customer Protection Rule with Respect to US Treasury Securities (Joint Trades)
SIFMA, SIFMA Asset Management Group, Managed Funds Association (MFA), Futures Industry Association (FIA), FIA Principal Traders Group (FIA PTG), International…
IOSCO Consultation Report on Digital Engagement Practices (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments on the International Organization of Securities Commissions’ (IOSCO) November 2024 Consultation Report on Digital…
Proposed Amendments to Rule 801 (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments on Maine Revenue Services' proposal regarding sourcing of receipts from services under the Maine…
Asset Management Fundamentals
These Asset Management Fundamentals explain common aspects of how asset managers operate. While some aspects are universal, such as the…
The Japan Securities Clearing Corporation’s Exemptive Order from Registration as a Derivatives Clearing Organization (Joint Trades)
SIFMA AMG, The Alternative Investment Management Association (AIMA), and Managed Funds Association (MFA) provided comments to the U.S. Commodity Futures…
Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (Joint Trades)
SIFMA AMG, MFA, AIMA, and IAA provided comments to the U.S. Securities and Exchange Commission (SEC0 and Commodity Futures Trading…
Notice of Partial Amendment No. 1 toProposed Rule Change to Adopt the FINRA Rule 6500 Series (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) regarding the partial amendment (the “Partial…
Targeted Consultation on the Functioning of the EU Securitization Framework (SIFMA AMG)
SIFMA AMG provided comments to the European Commission in response to their targeted consultation seeking views regarding the current EU…
Ongoing Data Collection of Non-Centrally Cleared Bilateral Transactions in the U.S. Repurchase Agreement Market, 12 CFR Part 1610 (SIFMA AMG)
SIFMA AMG provided comments to the Office of Financial Research (OFR) to seek clarification regarding certain aspects of the above-referenced…
Short Position and Short Activity Reporting by Institutional Investment Managers (Joint Trades)
SIFMA, SIFMA AMG, the Investment Company Institute (ICI), the Insured Retirement Institute (IRI), the FIA Principal Traders Group (FIA PTG),…
US Treasury Central Clearing: Industry Considerations Report
Dated: November 13, 2024 Introduction On December 13, 2023, the SEC voted 4-1 to approve a final rule, “Standards for…
Change in Bank Control Act Proposal (SIFMA AMG)
SIFMA AMG provided comments to the Federal Deposit Insurance Corporation (FDIC) on proposed changes to its regulations implementing the Change…
CFP Board’s Regulatory Regime for CFP Certificants
Dated: October 28, 2024 Executive Summary The Securities Industry and Financial Markets Association (“SIFMA”) is comprised of hundreds of member…
Financial Data Transparency Act Joint Data Standards (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provide comments to the Board of Governors of the Federal Reserve System (Federal Reserve) on the…
Financial Data Transparency Act Joint Data Standards (Joint Trades)
SIFMA, SIFMA AMG, Alternative Investment Management Association (AIMA), American Investment Council (AIC), Bank Policy Institute (BPI), Financial Services Forum (FSF),…
An Update on the Path to Clearing US Treasuries
In this episode of The SIFMA Podcast, we discuss the conversations at our recent SIFMA Operations Conference & Exhibition around…
SIFMA and SIFMA AMG Publish Master Treasury Securities Clearing Agreement
New York, NY, September 25, 2024 –SIFMA and SIFMA’s Asset Management Group (SIFMA AMG) today published the “2024 SIFMA Master…
Promoting Investor Success, Industry Innovation, and Efficiency with AI
Dated: September 10, 2024 Executive Summary The development and adoption of artificial intelligence (“AI”) in the financial services industry has…
SIFMA, SIFMA AMG Support Existing Risk-Based Rules to Govern AI
Washington, DC, September 10, 2024 – SIFMA and SIFMA’s Asset Management Group (SIFMA AMG) today issued a whitepaper on artificial intelligence…
NAIC: Financial Analysis Solvency Tools Working Group (E) – Complex Ownership Structures (SIFMA AMG)
SIFMA AMG provided comments to the National Association of Insurance Commissioners (NAIC) on the Financial Analysis Handbook Exposure Draft.
Proposed Rule Change Consisting of Amendments to MSRB Rule G-14 and to Amend FINRA Rule 6730 (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) and reiterated comments made in their…
Regulation NMS, Regulation Best Execution, and Order Competition Rule (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) regarding the outstanding equity market structure…
Request for Comment on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Department of the Treasury (DOT) on their request for information on…
CBOE Proposed Amendments for Listed CEFs (Joint Trades)
SIFMA, SIMFA AMG, the Investment Adviser Association (IAA), and the Insured Retirement Institute (IRI) provided comments to the U.S. Securities…
Proposed Rule Change To Adopt the FINRA Rule 6500 Series (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the proposed rule change to adopt the…
SIFMA AMG Statement on FDIC Consideration of Changes to Bank “Control” Rules
Washington, D.C., July 30, 2024 – SIFMA’s Asset Management Group (SIFMA AMG) today issued the following statement from Lindsey Keljo,…
Proposed Rule Change Amending Section 302.00 of the NYSE Listed Company Manual to Exempt Closed-End Funds Registered Under the Investment Company Act of 1940 from the Requirement to Hold Annual Shareholder Meetings (Joint Trades)
SIFMA, SIFMA AMG, the Investment Advisor Association (IAA), and the Insured Retirement Institute (IRI) provided comments to the U.S. Securities…
Request to Engage the CFTC on the Methodology for Developing Block Thresholds and Cap Sizes (Joint Trades)
SIFMA, SIFMA AMG, the International Swaps and Derivatives Association, Inc. (ISDA), the American Council of Life Insurers (ACLI), and the…
Joint Notice of Proposed Rulemaking on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Financial Crimes Enforcement Network (FinCEN) and the U.S. Securities and Exchange Commission…
EMIR 3 Initial Margin Model Validation (Joint Trades)
SIFMA AMG, the European Fund and Asset Management Association (EFAMA), the International Swaps and Derivatives Association (ISDA), and the Alternative…
Supplemental Information and Reopening of Comment Period for Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange” (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on Supplemental Information and Reopening of…
Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided supplemental comments to the Board of Governors of the Federal Reserve System, Office of the…
Fostering Liquidity and Resiliency in US Treasury Markets
Conversations from the ISDA/SIFMA Treasury Clearing Forum The U.S. Treasury market is the largest and most liquid bond market on…
The Path to Clearing US Treasuries
In this episode of The SIFMA Podcast, we outline recent and upcoming developments that will have a significant impact on…
Proposed Rule Change To Adopt the FINRA Rule 6500 Series (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Proposed Rule Change To Adopt the…
Proposed Amendments to S.5623/A.5290 (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to Senator Liz Krueger and Assemblymember Jessica González in response to proposed amendments to…
FICC Access Model and Customer Protection Proposals (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on Notice of Filing of Proposed Rule Change,…
The Dodd-Frank Underpinnings of the Securities and Exchange Commission’s Safeguarding Proposal
Status Quo Rather than an Expanded Mandate Dated: May 7, 2024 Introduction and Background: Over a year has passed since…
Dodd-Frank and Expanded SEC Authority over Investment Advisers: A Step Back
In this post, we discuss why the SEC’s 2023 custody proposal has significant potential impacts on clients, advisers, and other…
Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA AMG Statement on FDIC Postponing Rule Proposals on “Control”
Washington, D.C., April 25, 2024 – SIFMA’s Asset Management Group (SIFMA AMG) today issued the following statement from Lindsey Keljo,…
Request for Comment on the Use of Artificial Intelligence in CFTC Regulated Markets (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on their request for public comment on…
SIFMA Statement on FTC Non-Compete Rule Finalized Today
Washington, D.C., April 23, 2024 – SIFMA today issued the following statement from president and CEO Kenneth E. Bentsen, Jr.…
Potential Reevaluation of Certain Asset Managers’ Passive Investments in FDIC-Supervised Institutions (SIFMA AMG)
SIFMA AMG provided comments to the Federal Deposit Insurance Corporation (FDIC) on their consideration of various proposals to revise the…
Regulations to Address Margin Adequacy and To Account for the Treatment of Separate Accounts by Futures Commission Merchants (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on their withdrawal and proposal of a new…
Proposed Rule Change, as Modified by Partial Amendment No. 1, to Modify the GSD Rules to Facilitate Access to Clearance and Settlement Services of All Eligible Secondary Market Transactions in U.S. Treasury Securities (Joint Trades)
SIFMA, SIFMA AMG, the Investment Company Institute (ICI), Alternative Investment Management Association (AIMA), and the International Swaps and Derivatives Association…
Proposed Rule Change to Modify the GSD Rules (I) Regarding the Separate Calculation, Collection and Holding of Margin for Proprietary Transactions and That for Indirect Participant Transactions, and (ii) To Address the Conditions of Note H to Rule 15c3-3a (Joint Trades)
SIFMA, SIFMA AMG, the Investment Company Institute (ICI), Alternative Investment Management Association (AIMA), and the International Swaps and Derivatives Association…
BCBS-CPMI-IOSCO Consultative Report Dated January 2024 on Transparency and Responsiveness of Initial Margin in Centrally Cleared Markets (SIFMA AMG)
SIFMA AMG provided comments to BCBS, CPMI, and ISOCO on their consultative report dated January 2024 on transparency and responsiveness…
Notice of Proposed Rulemaking on AML/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Financial Crimes Enforcement Network (FinCEN) on its proposed rule to impose certain…
Update on The Guidelines on Funds’ Names Using ESG or Sustainability-Related Terms (SIFMA AMG)
SIFMA AMG provided comments to the Investor Protections and Sustainable Finance Department on the Guidelines on funds’ names using ESG…
Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission on the Federal Power Act Section 203 Blanket Authorizations for…
The 2024 Asset Management Derivatives Forum Debrief
A Joint Publication from FIA Research and SIFMA Insights Recently, the Futures Industry Association (FIA) and the SIFMA Asset Management…
Public Country-by-Country Reporting (SIFMA AMG)
SIFMA AMG provided comments to the International Tax Unit on the refinements proposed in the Exposure Draft consultation published on…
SIFMA and SIFMA AMG Comment on One-Minute Trade Reporting Proposals
New York, NY, February 15, 2024 – In a comment letter filed with the SEC today, SIFMA and SIFMA AMG…
Proposed Rule Change to Amend MSRB Rule G–14 and FINRA Rule 6730 (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on SR-MSRB-2024-01 (the “MSRB Proposal”) filed…
December 2023 Consultation Document on the HMRC Pillar Two Guidance Manual (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to HM Revenue and Customs (HMRC) in response to their public consultation draft released…
Proposed Rule Change to Amend its Rules Relating to Position and Exercise Limits (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Proposed Rule Change to…
Proposed Amendments to CFTC Regulation 1.25 (SIFMA AMG)
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on the proposed amendments to CFTC Regulation 1.25.
SIFMA AMG Comments on Basel III Endgame and GSIB Surcharge Proposals
Washington, D.C., January 16, 2024 – SIFMA AMG today submitted a comment letter to the Office of the Comptroller of the…
Large Banking Organizations and Banking Organizations with Significant Trading and GSIB Surcharge Proposal (SIFMA AMG)
SIFMA AMG provided comments to the Office of the Comptroller of the Currency (OCC), the Board of Governors of the…
SIFMA, SIFMA AMG Comment on Long-Term Debt Requirement Proposal
Washington, D.C., January 11, 2023 – Today, SIFMA and SIFMA AMG submitted a comment letter to the Board of Governors…
Long-Term Debt Requirements (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Federal Reserve System, Office of the Comptroller of the Currency (OCC), and…
EU Sustainable Finance Disclosures Regulation (SIFMA AMG)
SIFMA AMG provided comments to the European Parliament and the Council of the European Union on sustainability‐related disclosures in the…
Proposed Amendments to Rule 4.7 (SIFMA AMG)
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on the proposed amendments to Rule 4.7 to (i)…
Open-End Fund Liquidity Risk Management Programs and Swing Pricing (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) in regards to Open-End Fund Liquidity…
FINRA Proposal on Treasury Transaction Public Dissemination (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the SEC’s FINRA proposal on public…
SIFMA AMG Comments on FSOC Nonbank SIFI Designation Guidance
Washington, D.C., November 4, 2023 – SIFMA’s Asset Management Group (SIFMA AMG) today issued the following comment regarding changes to…
Supplemental Comments on Safeguarding Advisory Client Assets (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided further comments to the U.S. Securities and Exchange Commission (SEC) on the proposed rule for…
SIFMA, SIFMA AMG Express Strong Concerns with SEC Proposed Rules on Predictive Data Analytics
Washington, D.C., October 10, 2023 – SIFMA and SIFMA AMG today submitted a letter to the Securities and Exchange Commission…
Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker- Dealers and Investment Advisers (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on proposed rules that would require…
Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants (SIFMA, SIFMA AMG, and ISDA)
SIFMA, SIFMA AMG, and the International Swap and Derivatives Association (ISDA) provided comments to the Commodity Futures Trading Commission (CFTC)…
Request for a delay to the compliance date for new Block Thresholds and Cap Sizes (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) requesting that the Division of Market Oversight (DMO)…
SEC and CFTC Clearing Agency Margin and Recovery and Wind-down Planning (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission…
House Committee on Education and the Workforce Markup of ERISA Bills H.R.5339, H.R.5337, H.R.5338, H.R.5340
House Committee on Education & the Workforce Markup of H.R.5339, H.R.5337, H.R.5338, H.R.5340 Thursday, September 14, 2023 Topline Markup of…
Negative Impacts of the Safeguarding Proposal on Investors, Market Participants, and the Financial Markets (Joint Trades)
26 trade associations provided comments to the U.S. Securities and Exchange Commission (SEC) regarding the Commission's proposed rule, Safeguarding Advisory…
Notice of Filing of Amendment to the National Market System Plan Governing the CAT (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Funding Proposal for the consolidated audit…
Financial Stability Board Consultation Report on Liquidity Risk Management of Open-End Funds (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the Financial Stability Board’s (FSB) July 2023 Consultation Report on liquidity risk management…
IOSCO Consultation Report on Liquidity Risk Management Tools (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the International Organization of Securities Commissions' (IOSCO) July 2023 Consultation Report on proposed…
Position Reporting of Large Security-Based Swap Positions (SIFMA AMG)
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) in response to the Commission’s reopening of the comment…
Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker Dealers and Investment Advisers (Joint Trades)
SIFMA, SIFMA AMG, American Council of Life Insurers (ACLI), Alternative Investment Management Association (AIMA), American Investment Council (AIC), Financial Services…
SIFMA AMG Comments on FSOC Nonbank SIFI Designation Proposal
Washington, D.C., July 27, 2023 – SIFMA’s Asset Management Group (SIFMA AMG) today submitted comments regarding changes to guidance on…
Authority to Require Supervision and Regulation of Certain NBFCs (SIFMA AMG)
SIFMA AMG submitted comments to the Financial Stability Oversight Council (FSOC) in response to its proposed interpretive guidance and proposed…
Making Multinationals Pay Their Fair Share-Integrity and Transparency (SIFMA AMG)
SIFMA AMG provided their views to the Economics Legislation Committee on U.S. and global policy and to create industry best…
SIFMA Statement on Final SEC Money Market Fund Rule
Washington, D.C., July 12, 2023 – SIFMA today issued the following statement from president and CEO Kenneth E. Bentsen, Jr.…
SIFMA Statement on House Passage of Bill Related to MiFID II No-Action Relief
Washington, D.C., July 11, 2023 – SIFMA today issued the following statement from president and CEO Kenneth E. Bentsen, Jr.…
Joint Consultation Paper on the review of SFDR Delegated Regulation (SIFMA AMG)
SIFMA AMG provided comments to the Joint Committee of the European Supervisory Authorities on the review of SFDR Delegated Regulation…
Derivatives Clearing Organization Risk Management Regulations to Account for the Treatment of Separate Accounts by Futures Commission Merchants (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on the proposed amendments to its derivatives clearing…
Request for Extension to the Comment Period for Covered Clearing Agency Resilience and Recovery and Wind-Down Plans (Joint Trades)
SIFMA, SIFMA AMG, Futures Industry Association (FIA), Internal Swaps and Derivatives Association (ISDA), Managed Funds Association (MFA), and Investment Company…
Reopening of Comment Period for Proposed Rulemaking on Modernization of Beneficial Ownership Reporting (SIFMA and SIFMA AMG)
SIFMA and SIMFA AMG provided comments to the Securities and Exchange Commission (SEC) on the reopening of its Modernization of…
SIFMA, SIFMA AMG Express Concerns with SEC Proposal to Redefine Exchanges
New York, NY, June 14, 2023 – In a comment letter filed with the SEC, SIFMA broadly supports the policy…
Supplemental Information and Reopening of Comment Period for Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange” (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on Supplemental Information and Reopening of Comment Period…
Future of Operations: Scaling Alternative Assets
There is no universal definition of alternative asset classes. Although there is some broad agreement that assets like private equity…
Safeguarding Advisory Client Assets (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the proposed new rule for safeguarding advisory…
SIFMA Statement on FSOC Nonbank SIFI Designation Proposal
Washington, D.C., April 21, 2023 – SIFMA today issued the following statement from SIFMA’s Asset Management Group (SIFMA AMG) regarding…
Troubled Waters for Mutual Fund Liquidity Regulation
In November of 2022, the SEC issued a rule proposal that seeks to mandate how U.S. open-end mutual funds manage…
Notice of Proposed Rulemaking, Federal Trade Commission; Non-Compete Clause Rule; 88 Fed. Reg
SIFMA and SIFMA AMG provided comments to the Federal Trade Commission (FTC) on the proposed near-total ban of worker non-compete…
Equity Market Structure Proposals (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on Regulation Best Execution, Order Competition Rule, Regulation…
SIFMA and SIFMA AMG Raise Concerns Over SEC’s Proposed Securitization Rule
New York, NY, March 28, 2023 – In a comment letter filed with the Securities and Exchange Commission (SEC) in…
Request for Public Comment Regarding Proposed Rule 192 (SIFMA, SIFMA AMG and BPI)
SIFMA, SIFMA AMG and the Bank Policy Institute (BPI) provided comments to the U.S. Securities and Exchange Commission (SEC) on…
OFR Proposed Rule Change Relating to Collection of Non-Centrally Cleared Bilateral Transactions in the US Repurchase Agreement Market (SIFMA AMG)
SIFMA AMG provided comments to the Office of Financial Research (OFR) on their proposed rule establishing a data collection regime…
The 2023 Asset Management Derivatives Forum Debrief
Perspectives and Key Themes from Market Participants Recently, the Futures Industry Association (FIA) and the SIFMA Asset Management Group (AMG)…
ESMA Consultation Paper regarding Guidelines on funds’ names using ESG or sustainability-related terms
SIFMA AMG provided comments to The European Securities and Markets Authority (ESMA) on their Consultation Paper regarding Guidelines on funds’…
SIFMA, SIFMA AMG Submit Comments on Swing Pricing and Open-End Fund Liquidity Risk Management Programs
Washington, DC, February 14, 2023 – SIFMA and SIFMA Asset Management Group (SIFMA AMG) today filed comment letters expressing strong…
Open-End Fund Liquidity Risk Management Programs and Swing Pricing Comments on Proposal to Amend Liquidity Risk Management and Reporting Rules (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Commission’s proposal to make certain revisions…
Open-End Fund Liquidity Risk Management Programs and Swing Pricing Comments on Proposal to Mandate Swing Pricing and a Hard Close (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Commission’s proposals to make certain revisions…
FIA-SIFMA Flash Poll Measures Derivatives Markets Sentiment
FIA and SIFMA's Asset Management Group conducted a joint poll of their members during January to capture buyside and sellside views on…
Investment Adviser Recordkeeping Requirements (Joint Trades)
SIFMA, SIFMA AMG, Managed Fund Association (MFA), U.S. Chamber of Commerce, American Securities Association (ASA), National Venture Capital Association (NVCA),…
FINRA Requests Comment on Proposed Changes to TRACE Reporting Relating to Delayed Treasury Spot Trades
SIFMA and SIFMA AMG provided comments to the Financial Industry Regulatory Authority (FINRA) on Regulatory Notice 22-26 (the 2022 RN),…
Sustainability Disclosure Requirements and Investment Labels (SIFMA AMG)
SIFMA AMG provided comments to the Financial Conduct Authority (FCA) on their consultation on Sustainability Disclosure Requirements and Investment Labels.
Outsourcing by Investment Advisers
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the proposed new rules and amendments governing outsourcing…
Standards for Covered Clearing Agencies for US Treasury Securities and Application of the Broker-Dealer Customer Protection Rule (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on its proposed rule regarding Standards for Covered…
A Primer on the Regulatory Landscape for Asset Managers
Lindsey Keljo, head of SIFMA's Asset Management Group, provides an overview of the current regulatory landscape for asset managers.
Open-End Fund Liquidity Risk Management Programs and Swing Pricing, Form N-PORT; Outsourcing by Investment Advisers (Joint Trades)
SIFMA AMG, Loan Syndications and Trading Association (LSTA), Investment Company Institute (ICI), Investment Adviser Association (IAA), American Investment Council (AIC),…
Need for Continued MiFID II Relief: Overview of Key Issues and Challenges under the Advisers Act
SIFMA provided comments to staff of the Division of Investment Management of the Securities and Exchange Commission (SEC) to explain…
Governance Requirements for Derivatives Clearing Organizations (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on the proposal to formalize and standardize governance…
Clearing Agency Governance and Conflicts of Interest (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the proposal to formalize and standardize governance…
Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) and U.S. Securities and Exchange Commission (SEC) on their…
Comments on CFTC Request for Information on Climate-Related Financial Risk (SIFMA, SIFMA AMG and IIB)
SIFMA, SIFMA AMG, and the Institute of International Bankers (the IIB) provided comments to the Commodity Futures Trading Commission (CFTC)…
Margin requirements for non-centrally cleared derivatives: Amendments to BTS (Joint Trades)
SIFMA AMG, Investment Company Institute (ICI), International Money Market Funds Association (IMMFA), International Swaps Derivatives Association (ISDA) and UK Finance…
MSRB Notice 2022-07 and FINRA Regulatory Notice 22-17 – Proposals to Shorten Fixed Income Trade Reporting Timeframes
SIFMA and SIFMA AMG provided comments to the Municipal Securities Rulemaking Board (MSRB) and Financial Industry Regulatory Authority (FINRA) on…
Response to CPMI and IOSCO’s Discussion Paper on CCP to Address Non-default Losses (SIFMA AMG)
SIFMA AMG provided comments to the Committee on Payments and Market Infrastructures (CPMI) and the Board of the International Organization…
Proposed Trade Reporting Requirements for OTC Options Transactions
SIFMA and SIFMA AMG provided comments to the Financial Industry Regulatory Authority, Inc. (FINRA) on its Regulatory Notice 22-14. In…
Money Market Fund Reforms (SIFMA AMG and ICI)
SIFMA AMG and the Investment Company Institute (ICI) provided comments to the U.S. Securities and Exchange Commission (SEC) on the…
Extension Request for the Form PF Proposed Rules (Joint Trades)
SIFMA AMG, the Managed Funds Association (MFA), The Alternative Investment Management Association (AIMA), Alternative Credit Council (ACC) , American Investment…
NASAA REIT Proposal
SIFMA AMG provided comments to the North American Securities Administrators Association (NASAA) on the Proposed Revisions to the NASAA Statement…
Additional Transparency for Secondary Market Transactions of Treasury Securities (SIFMA AMG)
SIFMA's Asset Management Group (SIFMA AMG) submits comments to the U.S. Department of the Treasury’s recent request for information (“RFI”)…
Certain Information Providers Acting as Investment Advisers (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the their Request for Comment…
The Names Rule Amendments Proposal (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on their proposed rule and form amendments pertaining…
ESG Investment Practices (SIFMA AMG)
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on their proposal to enhance disclosures by certain…
SIFMA AMG Response to ISSB Sustainability Disclosures
The Asset Management Group of the Securities Industry and Financial Markets Association (SIFMA AMG) provided comments on the Exposure Drafts…
SIFMA AMG Request for Extension of CFTC Staff Letter 19-19
SIFMA AMG, the Futures Industry Association (FIA) and Managed Funds Association (MFA) provided comments to the Division of Market Oversight…
SIFMA AMG Response to IOSCO’s Discussion Paper: Corporate Bond Markets – Drivers of Liquidity During COVID-19 Induced Market Stresses
The Asset Management Group of the Securities Industry and Financial Markets Association (SIFMA AMG) provided comments on the International Organization…
SIFMA AMG on SEC Climate-Related Disclosures for Investors
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on the Commission's proposal to enhance and standardize…
SIFMA AMG Supplemental Comments on Private Fund Advisers Proposal
SIFMA AMG provided supplemental comments to the Securities and Exchange Commission (SEC) on the Commission’s proposed new rules and amendments…
SIFMA AMG on SEC SBS Execution Facilities
SIFMA's Asset Management Group (SIFMA AMG) provided comments to the U.S. Securities and Exchange Commission (the “Commission”) on the proposed…
SIFMA AMG Comment – LME’s Proposal to Collect OTC Metals Positions
SIFMA AMG provided comments to the The London Metal Exchange and LME Clear (LME) regarding the Consultation on OTC Position…
SIFMA AMG on SEC “Dealers” Proposal
SIFMA Asset Management Group (SIFMA AMG) provided comments to the Securities and Exchange Commission (SEC) on the Proposed Rules that…
Joint Trades IAWG Letter on SEC Dealer Proposal
SIFMA Asset Management Group (SIFMA AMG) in a joint letter with other associations provided comments regarding the Securities and Exchange…
Joint Trades Request for Extension of Comment Period on Dealer Proposal
SIFMA, SIFMA Asset Management Group (SIFMA AMG), Managed Funds Association (MFA), Investment Adviser Association (IAA), The Alternative Investment Management Association…
SIFMA AMG on FINRA Complex Products and Options
SIFMA AMG provided comments to FINRA on Notice 22-08, Complex Products and Options. SIFMA AMG’s comments will focus only on…
SIFMA AMG on ESMA Consultation on ESG Ratings Providers
SIFMA AMG provided comments to European Securities and Markets Authority (ESMA) in response to their ESMA Consultation on ESG Ratings…
SIFMA AMG on ESMA Suitability Guidelines
SIFMA AMG provided comments to European Securities and Markets Authority (ESMA) in response to their Consultation Paper regarding Guidelines on…
SIFMA and SIFMA AMG on SEC Short Reporting Proposal
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission’s (SEC) release on proposed Rule 13f-2 under…
SIFMA AMG on Private Fund Advisers Proposal
SIFMA AMG provided comments to the United States Securities and Exchange Commission (SEC) on the Commission’s proposed new rules and…
SIFMA AMG on Common Ownership Questions
SIFMA AMG provided comments to the Antitrust Division of the United States Department of Justice and the United States Federal…
SIFMA AMG Comments on Proposed Changes to Money Market Rules
Washington, D.C., April 11, 2022 – SIFMA and SIFMA AMG today summited comments to the U.S. Securities and Exchange Commission…
SEC Cybersecurity Risk Management Proposals
SIFMA and SIFMA AMG provided comments on the proposed new cybersecurity risk management rules and amendments issued by the Securities…
SIFMA and SIFMA AMG on SEC Money Market Fund Proposal
SIFMA and SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) with respect to the Commission’s request…
SEC Proposed Amendments to Beneficial Ownership (SIFMA AMG )
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the Modernization of Beneficial Ownership Reporting. See Also:…
The SIFMA Podcast: A Primer on Proposed Reforms to Money Market Fund Rules
In this episode of The SIFMA Podcast, SIFMA President & CEO Kenneth E. Bentsen, Jr. sits down with Lindsey Keljo…
SIFMA AMG on SEC Form PF Proposal
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the Commission’s proposed amendments to Form PF.
SIFMA AMG comments on Security-Based Swap Position Reporting (10B-1) and Anti-Fraud and Manipulations (9j-1) Requirements Proposal
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the security-based swap position reporting requirements set forth…
SIFMA Promotes Lindsey Keljo to Head of Asset Management Group
Washington, D.C., March 14, 2022 – SIFMA today announced Lindsey Keljo has been promoted to head the association’s Asset Management…
Discussion Paper on Client Clearing
SIFMA AMG appreciates the important work of CPMI and IOSCO in assessing issues related to developing models for client clearing and…
Joint Trades Response to EBA Technical Standards for Initial Margin Model Validation
SIFMA AMG, ISDA, and ESBG appreciate the opportunity to respond to the Draft Regulatory Technical Standards on Initial Margin Model…
SIFMA AMG on Application of SFDR entity-level rules to Article 42 AIFMs
SIFMA AMG provided comments to the European Commission on U.S. and global policy and to create industry best practices.
Consultative Report on Review of Margin Practices
SIFMA AMG appreciates the important work of BCBS, CPMI and ISOCO (collectively, the “Supervisory Authorities”) in performing an analysis –…
SIFMA, SIFMA AMG Submit Comment Letters on SEC Proposal on Reporting of Securities Loans
Washington, DC, January 10, 2022 – SIFMA and SIFMA AMG submitted a pair of comment letters on the U.S. Securities…
SIFMA AMG on Reporting of Securities Loans
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on proposed Rule 10c-1 under the Securities Exchange Act of…
Feedback on Sustainability Disclosure Requirements and Investment Labels
SIFMA AMG (SIFMA Asset Management Group) provided feedback to the Financial Conduct Authority (FCA) on their Discussion Paper: DP21/4 -…
SIFMA AMG Statement on Launch of the International Sustainability Standards Board
Washington, D.C., November 3, 2021 – SIFMA AMG today released the following statement from Tim Cameron, SIFMA Managing Director and…
Proposed Regulation 172 (SIFMA AMG)
SIFMA AMG provided comments to the New York State Department of Financial Services on the Department of Financial Services’ (DFS)…
Future of Operations: Simplifying Operations with Data
Firms are conducting wide-ranging overhauls designed to integrate data and analytics into workflows. The aim? Radically enhance the value of…
SIFMA AMG Statement on Impact of Tax Proposals on Middle-class Savers
Washington, D.C., September 17, 2021 – SIFMA AMG today released the following statement from Tim Cameron, SIFMA Managing Director and…
Joint Trades on Equivalence and Recognition in Relation to UK CCPs
SIFMA AMG and joint trade associations provided comments to the European Commission on the work they have carried out so…
SIFMA and SIFMA AMG on Amendment to FINRA 4210 – Margin Rules for Covered Agency Transactions
SIFMA and The Asset Management Group of SIFMA (SIFMA AMG) provided comments to the Commission’s consultation on FINRA’s Amendment No.…
SEC AMAC Meeting
Securities and Exchange Commission Asset Management Advisory Committee (AMAC) Wednesday, July 7, 2021 Welcome and Opening Remarks Chair Gary Gensler…
Proposed Changes to SASB Asset Management & Custody Activities Standard
SIFMA AMG provided comments to the Sustainability Accounting Standards Board (SASB) in response to their proposal to remove the Systemic…
SEC Climate Change-Related Disclosure rules
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on issues to consider as the SEC evaluates creating…
FTC’s Misguided Efforts to Capture Anticompetitive Behavior Will Ultimately Harm the same Investors it Seeks to Protect
Late last year, the Federal Trade Commission (FTC), with the concurrence of the Antitrust Division of the U.S. Department of…
Eligible Collateral under UK Margin BTS – EEA UCITS (Joint Trades)
SIFMA AMG, The Alternative Investment Management Association (AIMA), the Institutional Money Market Funds Association (IMMFA), the Investment Company Institute (ICI),…
Potential Rulemaking to Rule 17a-7 as it Relates to Cross Trading
SIFMA AMG provided comments to the SEC on potential rulemaking related to Rule 17a-7 under the Investment Company Act of…
Potential Reform Measures for Money Market Funds
SIFMA AMG provided comments to the SEC with respect to the Commission’s request for comment on potential reform measures for…
CCP Evaluation Framework
For asset managers who have material exposure in centrally cleared derivatives, clearing risks should be considered in a comprehensive counterparty…
Hart-Scott-Rodino Coverage, Exemption, and Transmittal Rules
SIFMA AMG provided comments on the publication by the Federal Trade Commission (“Commission”), with the concurrence of the Antitrust Division…
European Commission Public Consultation on the Review of the AIFMD
This response is made on behalf of the Asset Management Group of SIFMA (“SIFMA AMG”) and the Asset Management Group…
Climate-related Financial Disclosures Forward-Looking Financial Sector Metrics Consultation
SIFMA AMG response to the Task Force on Climate-related Financial Disclosures Forward-Looking Financial Sector Metrics Consultation.
Joint Trades on Equivalence – Derivatives Trading Obligation (DTO)
SIFMA and joint trades provided comments to the European Commission in reference to recognizing the equivalence of United Kingdom (UK)…
Insurance Regulation 172
SIFMA's Asset Management Group (SIFMA AMG) provided comments to the New York State Department of Financial Services (DFS) on the…
Consultation on the development of the CFA Institute ESG Disclosure Standards for Investment Products
CFA Institute is developing a voluntary, global industry standard, the CFA Institute ESG Disclosure Standards for Investment Products (the “Standard”),…
Future of Operations: Changing the Nature of Work
Workplaces in the financial services industry were already in the midst of a dramatic transformation when COVID-19 introduced an unprecedented…
Margin and Capital Requirements for Covered Swap Entities, Interim Final Rule
SIFMA and joint trades provided comments to the Office of the Comptroller of the Currency, Federal Housing Finance Agency, Federal…
Sample Provisions for FCM Customer Agreements for Separate Accounts
SIFMA AMG and FIA and Release Sample Provisions for FCM Customer Agreements for Separate Accounts
IFR and Proposed Rules Extending Phase 5 and 6 Compliance Dates for Regulatory Initial Margin
SIFMA and joint trades provided comments to the Commodity Futures Trading Commission (CFTC) on Margin Requirements for Uncleared Swaps for…
Securities and Exchange Commission Open Meeting
Securities and Exchange Commission Open Meeting Wednesday, August 5, 2020 Opening Statements Chairman Jay Clayton In his opening statement, Clayton…
Consultation on the renewed sustainable finance strategy
On 11 December 2019, the European Commission adopted its Communication on a European Green Deal, which significantly increases the EU’s…
Good Faith Determinations of Fair Value
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on their Fair Valuation Proposal.
Joint AMG-MFA Response to the CFTC Proposal to Amend their Part 190 Bankruptcy Regulations
SIFMA AMG and MFA provided comments to the CFTC on their proposal to amend the Commission’s bankruptcy regulations contained in…
Investment Adviser Advertisements and Solicitation Supplemental Proposal
SIFMA AMG provided comments to the SEC on the proposed amendments to the rules governing investment adviser advertisements and solicitation…
CFTC Proposal to Amend the Commission Regulations Related to Real-Time Public Reporting Requirements (Part 43)
SIFMA AMG provided comments to the CFTC on the proposal to amend their real-time public reporting requirements with respect to:…
SEC Request for Comments on Fund Names
SIFMA AMG provided comments to the SEC on the Commission’s request for public comment on the framework for addressing names…
The Future of Client Onboarding
New approaches from leading buy-side and sell-side firms for client lifecycle management Download Report Excerpt Onboarding: On the…
Joint Consultation Paper concerning ESG disclosures
SIFMA AMG welcomes the opportunity to provide the European Supervisory Authorities (ESAs) with feedback on the draft Regulatory Technical Standards…
CFTC Agricultural Advisory Committee Meeting
Commodity Futures Trading Commission Agricultural Advisory Committee Meeting Wednesday, April 22, 2020 Opening Statements Chairman Heath P. Tarbert In his…
Use of Derivatives by Registered Investment Companies and Business Development Companies Proposal
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on use of Derivatives by Registered Investment Companies and…
Margin Requirements for Non-Centrally Cleared Swaps Margin – Impact of COVID-19 on IM Phase-In
SIFMA and the SIFMA Asset Management Group (SIFMA AMG) along with joint trades provided comments to Basel Committee on Banking…
Investment Adviser Advertisements in Investment Advisers Act Release
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC or Commission) on the proposed changes to the rules…
Compensation for Solicitations in Investment Advisers Act Release
SIFMA AMG provided comments to the Securities and Exchange Commission on the proposed changes to the cash solicitation rule in…
Joint Trades on Margin and Capital Requirements for Covered Swap Entities
SIFMA AMG and ACLI provided comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal…
Joint Trades on Temporary Equivalence and Recognition in relation to UK CCPs
SIFMA AMG and joint trades provided comments to the European Commission on the continuity of access for EU members to…
Concept Release on Harmonization of Securities Offering Exemptions
SIFMA provides comments to the Securities and Exchange Commission (SEC) in response to request for public comment on registration exemptions…
Podcast: Where Money Market Funds and the Repo Market Intersect
Money market funds are a significant source of cash for the repo markets, lending to broker-dealers or hedge funds in…
Remaining Stage of Initial Margin Phase-In for the Margin Requirements for Non-Centrally Cleared Derivatives
SIFMA’s Asset Management Group (SIFMA AMG) submitted a letter to global and U.S. Regulators in regards to several scoping and implementation…
Derivatives Clearing Organization General Provisions and Core Principles
SIFMA’s Asset Management Group (SIFMA AMG) provided comments to the Commodity Futures Trading Commission (CFTC) proposed amendments to the Derivatives…
Request for Clarification of Cross-Border Statements in Part 4 Proposal Preamble
SIFMA AMG, the IAA, Willkie, Farr & Gallagher, and Fried, Frank, Harris, Shriver & Jacobson LLP submitted a letter to…
Joint Comments on the Importance of Buy-Side Participation in CCP Default Management Auctions
The Asset Management Group of SIFMA (SIFMA AMG) provided comments jointly with the Managed Funds Association (MFA) to the Bank…
Extension of SIFMA No-Action Letter
SIFMA and SIFMA AMG agree with the recommendations of the SEC Investor Advisory Committee at its July 25, 2019 meeting…
What Asset Managers Need to Know About SOC Reports
With many recent changes to the System and Organization Controls (SOC) reports guidelines, SIFMA AMG and BDO have prepared this…
Future of Operations: Finding a Home for Fintech
Could new technologies free your workforce from ‘soulless business processes’ and allow them to focus on value-added client engagement? In…
SIFMA AMG Request for Interpretation to CFTC Regarding Commodity Futures Trading Commission Rules 1.56(b) and 39.13(g)(8)(iii)
SIFMA AMG submitted a request for interpretation to the CFTC’s Division of Clearing and Risk and the Division of Swap…
CBOE Proposal on Continued Listing Standards
SIFMA AMG sent comments in opposition to the Order of Disapproval issued by the Division of Trading and Markets of…
FSOC Interpretive Guidance Proposal
SIFMA AMG provided comments to the Financial Stability Oversight Council in response to its proposed Interpretive Guidance (“Proposal” or “Proposed…
Non-Cleared Derivatives Initial Margin (IM)
SIFMA Asset Management Group’s (AMG) Non-Cleared Derivatives IM Questionnaire and Supporting Annex
Fund of Funds Rule
SIFMA AMG sent comments to the United States Securities and Exchange Commission on the Commission’s proposed new Rule 12d1-4 under…
IOSCO Sustainability Consultation
SIFMA AMG provided comments to the International Organization of Securities Commissions on the consultation report on Sustainable Finance on Emerging…
ESMA Liquidity Stress Testing Consultation
SIFMA AMG sent comments to the European Securities and Markets Authority’s consultation on its draft guidelines on Liquidity stress testing…
SEC Cross-Trading Letter
SIFMA AMG sent a request for clarification of no-action relief under Rule 17a-7. We request that the Staff confirm that…
FCA Consultation Paper on Proposals to Improve Shareholder Engagement
SIFMA AMG provided comments to the Financial Conduct Authority on the FCA’s Consultation on proposals to improve shareholder engagement which…
SEC Request for Comment on Earnings Releases and Quarterly Reports
SIFMA's Asset Management Accounting Policy Committee along with The Global Financial Institutions Accounting Committee as representatives of preparers of earnings…
Proposed Standardized Approach for Calculating the Exposure Amount of Derivative Contracts
SIFMA AMG and Managed Funds Association (MFA) provide comment to the Board of Governors of the Federal Reserve System, the…
Swap Execution Facilities and Trade Execution Requirement Proposed Rule and Post-Trade Name Give-up on Swap Execution Facilities
The Asset Management Group of SIFMA (SIFMA AMG) provided comments to the Commodity Futures Trading Commission (CFTC) on their proposed…
SIFMA Statement on Basel and IOSCO Guidance on Final Implementation Phases of the Margin Requirements
Washington, DC, March 5, 2019 – SIFMA today issued the following statement from Kenneth E. Bentsen, Jr., SIFMA president and…
Brexit – equivalence of UK derivatives trading venues under EMIR and MiFIR
FIA, the International Swaps and Derivatives Association, the Alternative Investment Management Association, the Association for Financial Markets in Europe, Associazione…
Exchange-Traded Funds
SIFMA AMG's ETF Committee provided comments to the United States Securities and Exchange Commission on the Commission’s proposed new Rule…
SIFMA AMG Common Ownership Letter
The Asset Management Group of SIFMA appreciates the opportunity to provide comments to the United States Federal Trade Commission in…
Leverage Ratio Treatment of Client Cleared Derivatives
SIFMA AMG and Managed Funds Association responded to the Basel Committee’s consultative document on the leverage ratio treatment of client cleared derivatives.…
Proposed Amendments to Registration and Compliance Requirements for Commodity Pool Operators
The Asset Management Group of SIFMA (SIFMA AMG) provided comments to the Commodity Futures Trading Commission (CFTC) on their Notice…
Timing and Substantive Concerns Related to No-Action Relief for Dealing Commissions
SIFMA AMG appreciates the continued dialogue with the Securities and Exchange Commission staff regarding our members’ concerns related to the…
Joint Consultation Paper Concerning Amendments to the PRIIPs KID
SIFMA Asset Management Group (SIFMA AMG) provides response to the European Supervisory Authorities’ (ESAs) on their consultation paper concerning amendments…
Unrelated Business Taxable Income
SIFMA AMG provided input to the U.S. Department of the Treasury and Internal Revenue Service’s request for comments to Notice…
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
SIFMA AMG provides comments to the Securities and Exchange Commission (SEC) in regards to the reopening of the comment period…
It’s time to address FSOC’s designation process
Over the last decade, much of the recent regulatory activity in the asset management space was prompted by (or occurred…
FCA Call For Input on the PRIIP’s Regulation
SIFMA AMG provided feedback to the Financial Conduct Authority (FCA) on PRIIP's regulation call for input on the PRIIPs Regulation. On behalf of…
SEC’s ETF Rulemaking
SIFMA AMG provided comments to the SEC on the Commission’s proposed new Rule 6c-11 under the Investment Company Act of…
SIFMA Submits Comments to the SEC on Regulation Best Interest
Washington, DC, August 7, 2018 - SIFMA today responded to the Securities and Exchange Commission (SEC) request for comment on…
Standard of Conduct for Investment Advisers
In a companion letter to SIFMA's comments to the SEC on Regulation Best Interest (Reg BI), SIFMA's Asset Management Group…
Governance Arrangements for the UPI
SIFMA AMG provided comments to the Financial Stability Board (FSB) on their second consultation regarding Unique Product Identifier (UPI) Governance. SIFMA AMG…
Investment Company Liquidity Disclosure
SIFMA AMG provided comments to the U.S. Securities and Exchange Commission (SEC) on their proposed amendments to its forms designed to…
Proposed Amendments to the CFTC Embargo Rule
SIFMA AMG provided comments to the CFTC on proposed amendments to the CFTC embargo rule. See also: Roadmap to Achieve…
Section 451(b) – Market Discount and Original Issue Discount (OID)
SIFMA AMG urged Treasury and the IRS to clarify in the near term that new Section 451(b) does not apply…
Phased-In Compliance Schedule Under the Qualified Financial Contract (QFC) Stay Rules
SIFMA AMG and ICI requested the Board of Governors of the Federal Reserve System, the Office of the Comptroller of…
Nominations and Suggested Agenda Items to the CFTC’s MRAC
SIFMA AMG recommends the CFTC’s Market Risk Advisory Committee (“MRAC”) consider the nominations of certain member firms, as well as,…
February 2017 Guidance on Custody
SIFMA and IAA provided comments to the SEC regarding the February 2017 guidance on custody. See also: February 2017 Guidance
Impact of Korean Capital Gains Tax on non-Korean CIVs
SIFMA AMG submitted a joint letter with other trade associations on behalf of our members' non-Korean CIVs and their investors,…
Impact of the European Commission’s Proposal to Amend Moratorium Powers Under the BRRD
SIFMA AMG and ICI Global submitted a letter to European Union policy makers providing data that supports concerns with the…
CFTC’s Rule Certification and Review Process for Registered Entities
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on the rule certification and review process under…
Future of Operations: Simplify, Innovate, Transform
The asset management industry is at a crucial juncture facing challenges that will transform the business. Asset management operations has…
Consultation Document on Funds Relationships in the Global Legal Entity Identifier System
SIFMA AMG, the Investment Adviser Association (IAA), the Investment Company Institute (ICI), and the Managed Funds Association (MFA), provided comments…
SIFMA AMG on FSB Consultation on UPI Governance
SIFMA AMG provides comment to the Financial Stability Board on the consultative report regarding Unique Product Identifier (UPI) governance. SIFMA…
G-SIB Surcharge Calculation
SIFMA AMG provides comments to the Federal Reserve System regarding Proposed Changes to G-SIB Surcharge Calculation. The Proposal would penalize the clearing…
SBS SDR Standards
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) regarding SBS SDR standards to address a recent request submitted…
Operational Risk: Tailoring the right model for asset management firms
When implementing an Operational Risk Management (ORM) program, complexity, firm size and resources may vary, but the underlying concept remains…
Joint Buy Side letter Regarding EU’s VM Requirements for Deliverable FX
Beginning in January 2018, EU investors subject to the European Market Infrastructure Regulation will face application of Variation Margin (VM)…
Project KISS
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on their Project KISS regulatory reform initiative. SIFMA…
CPMI and IOSCO Consultation Framework for Supervisory Stress Tests of CCPs
SIFMA AMG provides comments to CPMI and ISOSCO regarding the important work in formulating principles for supervisory stress tests of…
Open-End Fund Liquidity Risk Management Programs Rule
SIFMA AMG letter to Securities and Exchange Commission (SEC) Chairman Clayton, SEC Commissioner Stein, and SEC Commissioner Piwowar regarding Open-End Fund…
Proposed National Instrument 93-101
SIFMA AMG provided comments to the Canadian Securities Administrators (CSA) on Proposed National Instrument 93-101 Derivatives: Business Conduct and Proposed Companion…
Amended Application of DTCC Data Repository
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the amended application of DTCC Data Repository, LLC…
CFTC DMO Swaps Reporting Review and Roadmap
SIFMA Asset Management Group (SIFMA AMG) letter to the U.S. Commodity Futures Trading Commission (CFTC) Division of Market Oversight (DMO)…
Recommendations Regarding the Presidential Memorandum for the Secretary of the Treasury
SIFMA AMG provided recommendations to the U.S. Department of the Treasury as it develops the report required under the Presidential…
Supporting European Commission Proposal to Amend EMIR
SIFMA AMG provided comments to the European Commission (EC) regarding the EC’s legislative proposal to amend EMIR. Overall, SIFMA AMG…
Requesting No-Action Relief Relating to Position Aggregation Requirements
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) to request no-action relief relating to position aggregation requirements…
Proposed Moratorium Powers Under Bank Recovery and Resolution Directive
SIFMA AMG and ICI provided comment to the European Commission on the proposal amending Directive 2014/59/EU (BRRD) on loss-absorbing and…
The Trading Obligation for Derivatives Under MiFIR
SIFMA AMG provides comments to the European Securities and Markets Authority (ESMA) on their consultation paper on the trading obligation…
Asset Manager’s Guide to SOC 1
SOC 1 reports are typically requested by the customers of asset managers, such as pension funds and mutual funds. Asset…
Asset Manager’s Guide to SOC 1
SOC 1 reports are typically requested by the customers of asset managers, such as pension funds and mutual funds. Asset…
Central Counterparty Standards for Derivatives
SIFMA AMG, the American Council of Life Insurers, Investment Company Institute, Managed Funds Association, provided regulators with recommendations on central…
OFR: “An Approach to Financial Instrument Reference Data”
SIFMA AMG provides comments to the Office of Financial Research (OFR) with feedback on the OFR plan to standardize financial…
Updated Recommendations to the CFTC Regarding Swap Execution Facilities
SIFMA AMG provided updated recommendations to the U.S. Commodity Futures Trading Commission (CFTC) on optimization of the Commission’s Part 37…
CFTC’s Supplemental Proposal to Reg AT
SIFMA AMG provided comments to the U.S. Commodity Futures Trading Commission (CFTC) on the CFTC’s supplement (Supplemental Proposal) to proposed…
AMG Views on Core Principles for Regulating the US Financial System
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the U.S. Department of the Treasury as it develops its report…
Proposed Rule and Extension of Applicability Date Concerning the Definition of the Term “Fiduciary”
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration on…
Draft Consultation Document on Funds Relationships in the Global LEI System
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Legal Entity Identifier Regulatory Oversight Committee (LEI ROC) regarding its…
CFTC Regulation 1.31 on Recordkeeping
SIFMA AMG and Other Associations provided comments to the CFTC on recordkeeping. The Associations strongly support the Commission’s goals underlying…
Proposed 60-Day Fiduciary Rule Delay
SIFMA AMG recently submitted a comment letter to the Department of Labor on its proposed rule to extend the applicability…
FCA’s Interim Report on its Asset Management Market Study
SIFMA AMG provided comments to the Financial Conduct Authority (FCA) on their interim report on asset management market study. SIFMA…
SIFMA AMG Statement on CFTC Transition Period for Variation Margin Requirements
SIFMA AMG Statement on CFTC Transition Period for Variation Margin Requirements Washington, DC, February 14, 2017 – SIFMA’s Asset Management…
Designing a New Prudential Regime for Investment Firms
SIFMA AMG provided comments to European Banking Authority (EBA) on designing a new prudential regime for investment firms. The current…
Uncleared Swap Margin March 1 Variation Margin Requirements
The SIFMA Asset Management Group (SIFMA AMG) and the Investment Adviser Association (IAA) submitted a follow-up letter regarding its request…
FCA Consultation Paper on Transaction Cost Disclosure in Workplace Pensions
SIFMA AMG provided comments on Financial Conduct Authority (FCA) consultation paper on transaction cost disclosure in workplace pensions. SIFMA AMG…
AMG on CFTC’s Proposed Rules on Cross-Border Application
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on the Commission’s proposed rules regarding the cross-border application…
AMG Requests Relief from March 1, 2017 Variation Margin Implementation
SIFMA AMG requested relief for variation margin requirements applicable as of March 1, 2017 to counterparties not already included in…
Request for Comment Period Extension In Regards to Reg AT Proposal
SIFMA and the SIFMA Asset Management Group (SIFMA AMG), with the Futures Industry Association (FIA), FIA Principal Traders Group (FIA…
Trading Obligation for Derivatives Under MiFIR
SIFMA AMG provides comments to the European Securities and Markets Authority’s (ESMA) on thier discussion paper regarding the trading obligation…
Minimum Transfer Amount for Uncleared Swaps Margin Requirements
SIFMA AMG sent a letter to the Department of the Treasury’s Office of the Comptroller of the Currency, Board of…
Treatment of Initial Margin Under the Basel Leverage Ratio
SIFMA AMG and several other associations sent a letter to the Financial Stability Board (FSB), Governors and Heads of Supervision…
Consultative Report and FSB Discussion Note Regarding CCP Resiliency, Recovery and Resolution
SIFMA AMG has submitted comments on the CPMI-IOSCO Consultative Report and FSB Discussion Note, which, in combination, propose further guidance…
Consultation Paper Regarding Large Exposure Limits
SIFMA AMG has submitted comments on the proposed guidelines of the European Banking Authority (“EBA”) on the scope of the…
Mandatory Contractual Stay Requirements for Qualified Financial Contracts
SIFMA AMG comments on the notice of proposed rulemaking promulgated by the Office of the Comptroller of the Currency regarding…
SIFMA AMG Statement on Today’s SEC Rulemakings
Release Date: October 13, 2016 Contact: Katrina Cavalli, 212.313.1181, [email protected] SIFMA AMG Statement on Today’s SEC Rulemakings Washington, D.C., October…
Recommendations to Address Structural Vulnerabilities from Asset Management Activities
SIFMA's Asset Management Group (SIFMA AMG) appreciates the opportunity to comment on the consultative document, titled Proposed Policy Recommendations…
Exemption from Registration for Certain Foreign Persons
SIFMA AMG, IAA, and ICI Global comment letter on the CFTC’s Proposed Amendment to Regulation 3.10(c): Exemption from Registration for…
Business Continuity Planning, Transition Plans and Related Recordkeeping
SIFMA AMG provided comments to the (SEC) on Business Continuity Planning, Transition Plans and Related Recordkeeping. The AMG supports the…
Technical Standards for Uncleared Swaps Transactions
SIFMA AMG writes to express its concern regarding a change in the treatment of investment funds in the most recent…
Final Margin Rules for Uncleared Swaps Transaction
AMG supports the 30-day postponement of Phase I implementation of the U.S. Final Margin Rules requested by the International Swaps…
FINRA’s Proposed Rule Relating to the Reporting of U.S. Treasury Securities to TRACE
SIFMA provided comments to the Securities and Exchange Commission (SEC) Rule Filing SR-FINRA-2016-027, which would expand Trade Reporting and Compliance…
Proposed Net Stable Funding Ratio Requirement
SIFMA AMG and Financial Markets Association (“SIFMA AMG” or “AMG”) and Managed Funds Association (“MFA”) appreciate the opportunity to comment…
Proposed Rules Regarding Restrictions on Qualified Financial Contracts
SIFMA AMG provided comments on the notice of proposed rulemaking promulgated by the Board regarding a proposed rule that would…
Security-Based Swap Data Repositories
SIFMA AMG provided comments to the Securities and Exchange Commission (SEC) on the Application for Registration of DTCC Data Repository…
Proposed Clearing Mandate for Interest Rate Swaps
SIFMA AMG provides comments to the Commodity Futures Trading Commission (CFTC) regarding the Commission’s Notice of Proposed Rulemaking to mandate…
Supplemental Notice of Proposed Rulemaking on Exemptions for Position Limits
SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) regarding the Commission’s Supplemental Notice of Proposed Rulemaking on…
Section 385 Proposed Regulations
SIFMA AMG provided comments to the Internal Revenue Service (IRS) and the Department of Treasury (Treasury) regarding proposed regulations under…
FINRA’s Proposed Rule Change of Rule 2210
SIFMA AMG provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority’s (FINRA) proposed rule…
Revisions to the Basel III
SIFMA AMG, the Alternative Investment Management Association (AIMA), the Commodities Markets Council (CMC), the Investment Association (IA) and the Managed…
Banking Supervision on Revisions to the Basel III Leverage Ratio Framework
SIFMA AMG provides comments on the Basel Committee’s Consultative Document: Revisions to the Basel III Leverage Ratio Framework. SIFMA AMG…
Final Margin Rules for Uncleared Swaps Transactions
SIFMA AMG provides comment to multiple agencies to express its concern that the U.S. and Europe may no longer pursue…
The Proposed Rulemaking on Automated Trading
SIFMA AMG, Futures Industry Association (FIA), FIA Principal Traders Group (FIA PTG), Managed Funds Association (MFA) and International Swaps and…
Treatment of Security Conversion Transactions
SIFMA AMG, ASIFMA and AIMA Submit Comments to the Hong Kong Regulatory Regime on Treatment of Security Conversion Transactions.
SIFMA AMG Information Statement: Article 15 of the SFTR
SIFMA’s Asset Management Group (AMG) has prepared an information statement to address Article 15 of the EU’s Securities Financing Transaction…
The SCCL Proposal
SIFMA Asset Management Group (SIFMA AMG) provides comments to the Federal Reserve Board on the proposal to establish single-counterparty credit limits…
The Application for Registration of ICE Trade Vault LLC as a Security-Based Swap Data Repository
SIFMA AMG provides comment to the Securities and Exchange Commission (SEC) regarding the Application for Registration of ICE Trade Vault…
AMG on MSRB Notice 2016-11
SIFMA AMG provides comment to the Municipal Securities Rulemaking Board (MSRB) on a Concept Proposal to Improve Disclosure of Direct…
Standards for Covered Clearing Agencies
SIFMA AMG and the Investment Company Institute (ICI) provided comments to the Securities and Exchange Commission (SEC) to amend Rule…
The Amendment to the Bank Secrecy Act Regulations
SIFMA, SIFMA AMG and the American Bankers Association (ABA) provided comments to the Financial Crimes Enforcement Network (FinCEN) regarding proposed…
SIFMA AMG Derivatives Trading Package
SIFMA’s Asset Management Group (SIFMA AMG) has prepared a template client document that asset management firms can use to comply…
Treaty Entitlement of Non-CIV Funds
SIFMA’s Asset Management Group (SIFMA AMG) provides comments to the Organisation for Economic Co-operation and Development (OECD) in response to select…
The Puerto Rico Municipal Market and Contagion
SIFMA AMG provides comments to the Chair and Ranking Minority Member of the House Natural Resources Committee on pending legislation…
Treasury RFI on Evolution of the U.S. Treasury Market Structure
SIFMA AMG provides comments to the U.S. Treasury Department in response to their Request for Information (RFI) on the Evolution…
In Support of H.R. 3340: the Financial Stability Oversight Council Reform Act
SIFMA provides comments to US House of Representatives Speaker Paul Ryan and Minority Leader Nancy Pelosi in support of H.R.…
Open-End Fund Liquidity Risk
SIFMA AMG provides supplemental comments to the U.S. Securities and Exchange Commission (SEC) on the Commission's proposal to require liquidity…
SIFMA AMG Institutional Exception Model Letter
SIFMA’s Asset Management Group (AMG) has prepared the following letter to aid asset managers seeking to comply with the exception…
Proposed Rule 18f-4 to Establish Limits on the Size of Derivatives
SIFMA AMG provides comments to the U.S. Securities and Exchange Commission (SEC) on proposed rule 18f-4. The Proposed Rule seeks…
Relief on Final Margin Rules for Uncleared Swaps Transactions
SIFMA's Asset Management Group (SIFMA AMG) provides comments to Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of…
Proposed Regulation Automated Trading
SIFMA AMG provides comments to the Commodity Futures Trading Commission (CFTC) on their proposed Regulation Automated Trading. Many AMG members…
Managing Change in Asset Management
With new regulatory requirements and increasing business complexity, the amount of change taking place in the financial industry is unprecedented.…
The Consultative Report Regarding the Harmonisation of the Unique Product Identifier
SIFMA AMG provides comment to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions…
SIFMA AMG EMIR Classification Guide
SIFMA’s Asset Management Group (AMG) prepared the following client classification outreach letter in order to assist asset managers helping their…
TLAC Proposal
The Asset Management Group of the Securities Industry and Financial Markets Association submits the attached comment on the notice of…
Recovery Plan Guidelines
SIFMA, The Clearing House Association L.L.C. and the Financial Services Roundtable provide comments to the Office of the Comptroller of…
FINRA Rule 4210 Margin Requirements
SIFMA’s Asset Management Group (SIFMA AMG) provides supplemental comments to the Securities and Exchange Commission (SEC) on on SR-FINRA-2015-036, a…
No-Action Relief with CFTC’s Division of Swap Dealer and Intermediary Oversight
SIFMA’s Asset Management Group (SIFMA AMG) and the Investment Adviser Association (IAA) write to the Commodity Futures Trading Commission (CFTC)…
Banking Supervision on Higher Prices and Reduced Access to Clearing Experienced by Asset Managers
SIFMA AMG provided comments to the Basel Committee on Banking Supervision on higher prices and reduced access to clearing experienced…
Final Margin Rules for Uncleared Swaps Transactions
SIFMA AMG provided comments to raise a time-sensitive issue regarding the application of the final margin rules for uncleared swaps…
Proposal to Permit Swing Pricing on an Optional Basis
SIFMA’s Asset Management Group (SIFMA AMG) provides comments to the Securities and Exchange Commission (SEC) regarding the SEC’s proposed liquidity…
Proposed Requirements for Liquidity Risk Management Programs
SIFMA’s Asset Management Group (SIFMA AMG) provides comments to the Securities and Exchange Commission (SEC) regarding the SEC’s proposed liquidity…
Data Collection Rule Proposals to Enhance Reporting of Information
SIFMA's Asset Management Group (SIFMA AMG) and SIFMA's Asset Managers Forum (SIFMA AMF) provide further comments to the Securities and…
25 Investment Management Firms Commit to Single-Name CDS Clearing
25 Investment Management Firms Commit to Single-Name CDS Clearing NEW YORK, December 16, 2015 – The International Swaps and Derivatives Association,…
Regulation SBSR
SIFMA AMG provides comments to the Securities and Exchange Commission (SEC) on Regulation SBSR—Reporting and Dissemination of Security-Based Swap Information. SIFMA…
Proposed Rulemaking on Aggregation of Positions
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (Commission) regarding the Supplemental Notice of…
FINRA Rule 4210 regarding Margin Requirements for TBAs/Agency MBS
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Securities and Exchange Commission (SEC) on FINRA’s proposal to implement…
AML Program and Suspicious Activity Report Filing Requirements
SIFMA, SIFMA AMG and SIFMA’s Anti-Money Laundering & Financial Crimes Committee provide comments to the Department of the Treasury on…
Recommendations on Financial Risk Management of Central Counterparties
SIFMA's Asset Management Group (SIFMA AMG) provides a letter to the Committee on Payments and Market Infrastructures (CPMIA) and the…
Request for an Extension of No-Action Relief Letter 14-147
The Asset Management Group of SIFMA (SIFMA AMG) and Managed Funds Association (MFA) provide comments to the Commodity Futures Trading…
Operational Risk White Paper
When implementing an Operational Risk Management (ORM) program, complexity, firm size and resources may vary, but the underlying concept remains…
Cross Border Margin Proposal
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) regarding the cross-border application of…
Made Available to Trade Determinations
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Commodity Futures Trading Commission's (CFTC) Division of Market Oversight on…
The EMIR Review Consultation
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the European Commission (EC) on the EMIR Review Consultation. SIFMA AMG…
Investment Company Reporting Modernization
SIFMA's Asset Management Group (SIFMA AMG) provided comments to the Securities and Exchange Commission (SEC) on the Investment Company Reporting…
FSB’s Peer Review on Shadow Banking
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Financial Stability Board (FSB) in response to the request for feedback on…
DOL’s Fiduciary Rule Proposal
The Asset Management Group (the “AMG”) of SIFMA appreciates the opportunity to provide the U.S. Department of Labor’s (“Department”) Employee…
Proposed Rule Regarding Application of Certain Title VII Requirements to Security-Based Swap Transaction
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Securities and Exchange Commission (SEC) on the proposed rule regarding…
Second Consultation Paper Regarding Risk-Mitigation Techniques
SIFMA's Asset Management Group (SIFMA AMG) provides comments to The European Securities and Markets Authority, The European Banking Authority and…
SIFMA AMG Statement on IOSCO Strategic Direction Announcement
Release Date: June 17, 2015 Contact: Liz Pierce, 212-313-1173, [email protected] SIFMA AMG Statement on IOSCO Strategic Direction Announcement Washington, DC,…
Global Trade Reporting and Data Harmonization
SIFMA and the Asset Management Group of SIFMA (SIFMA AMG), The Australian Financial Market Association (AFMA), the Alternative Investment Management…
Fund Stress Testing Rulemaking
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the U.S. Securities and Exchange Commission (SEC) on Asset Management Fund…
SIFMA AMG Urges FSB and IOSCO to Drop Efforts to Create Systemic Risk Methodology for Asset Managers and Funds
Release Date: May 28, 2015Contact: Liz Pierce, 212-313-1173, [email protected] SIFMA’s Asset Management Group Urges FSB and IOSCO to Drop Efforts…
Assessment Methodologies for Identifying Non-Bank Non-Insurer Global SIFIs
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Financial Stability Board (FSB) on the FSB and the International…
Potential Market and Regulatory Changes to Strengthen Liquidity in the Fixed Income Markets
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the U.S. Securities and Exchange Commission on potential market and regulatory…
Commissioner Giancarlo’s White Paper and the SEF Regulatory Framework
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on the swap execution facility…
Asset Manager’s Guide to SOC 1
Grant Thornton released the “Asset Manager’s Guide to SOC I” following the SIFMA Asset Management Group’s (AMG) recent update of…
Proposed Rulemaking Regarding Qualified Financial Contracts Recordkeeping Related to Orderly Liquidation Authority
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Treasury Department on the Notice of Proposed Rulemaking regarding…
Bloomberg Application for Exemption from Registration as a Clearing Agency
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the Securities and Exchange Commission (SEC) regarding the Bloomberg application for…
FSB-IOSCO Consultation Documents
SIFMA's Asset Management Group (SIFMA AMG) provides comments to Department of the Treasury, Securities and Exchange Commission (SEC), Board of…
The Benchmark Survey of Financial Services Transactions
The Asset Management Group of SIFMA appreciates the opportunity to provide comments to the BEA on the proposed changes to…
SIFMA AMG and IAA Demonstrate that the Asset Management Industry Does Not Present Systemic Risk, Urge Deference to SEC in Comments to FSOC
Release Date: March 25, 2015 Contact: Liz Pierce, 212-313-1173, [email protected] SIFMA AMG and IAA Demonstrate that the Asset Management Industry…
Asset Management Products and Activities
The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”) and the Investment Adviser Association…
Dealing Commissions Regulation
SIFMA's Asset Management Group (SIFMA AMG) provided comments to the European Commission (EC) regarding the potential impact of the European…
ESMA Consultation Paper on Reporting Under Article 9 of EMIR
SIFMA's Asset Management Group (SIFMA AMG) provides comments to European Securities and Markets Authority (ESMA) on the Consultation Paper on…
Project Management White Paper
With the new regulatory requirements and increasing business complexity, the amount of change currently taking place in the financial industry…
Extension of Comment Period relating to Asset Management Products and Activities
SIFMA's Asset Management Group (SIFMA AMG) submitted a letter to the Financial Stability Oversight Council (FSOC) requesting FSOC extend for…
SIFMA Issues 2014 Year in Review
Release Date: January 14, 2015 Contact: Kate Zickel, 212.313.1102, [email protected] SIFMA Issues 2014 Year in Review New York, N.Y., January…
MiFID1 C6-C7
SIFMA's Asset Management Group (SIFMA AMG) provides comment to the European Securities and Markets Authority (ESMA) Consultation Paper regarding Guidelines…
The Consultation Draft of the Capital Markets Stability Act
SIFMA's Asset Management Group (SIFMA AMG) provided comments to the governments of Canada, British Columbia, New Brunswick, Ontario, Prince Edward…
The Nonbank Designation Process
SIFMA's Asset Management Group (SIFMA AMG), the American Council of Life Insurers (ACLI), the Financial Services Roundtable (FSR), and the…
Margin and Capital Requirements for Covered Swap Entities
SIFMA's Asset Management Group (SIFMA AMG) provided comments to multiple agencies, including the Commodity Futures Trading Commission (CFTC) and U.S.…
Basel III Leverage Rule Impact on Cleared Derivatives
The SIFMA Asset Management Group (SIFMA AMG) provides comments to Basel Committee on Banking Supervision, Bank for International Settlements (BIS) regarding…
Consultation Paper on the Clearing Obligation
SIFMA's Asset Management Group (SIFMA AMG) provides comments to European Securities and Markets Authority (ESMA) on the Consultation Paper on…
Discussion Paper on Calculation of Counterparty Risk by UCITS for Cleared OTC Derivatives
The SIFMA Asset Management Group (SIFMA AMG) provides comments to the European Securities and Markets Authority (ESMA) in response to the Discussion…
Requesting Further Relief relating to the Execution of Package Transactions
SIFMA Asset Management Group (SIFMA AMG), in a letter to the Commodity Futures Trading Commission (CFTC), is requesting further relief…
Volcker Rule Interpretations Regarding Foreign Public Funds and Foreign Non-Covered Funds
SIFMA's Asset Management Group (SIFMA AMG) wrote a letter to Scott Alvarez, General Counsel of the Board of Governors of…
Removal of Ratings and Diversification Requirements for 2a-7 Funds
SIFMA submitted a comment letter to the Securities and Exchange Commission (SEC) regarding the removal of ratings and issuer diversification…
SIFMA Statement on the New ISDA Resolution Stay Protocol
Release Date: October 11, 2014 Contact: Katrina Cavalli, 212.313.1181, [email protected] SIFMA Statement on the New ISDA Resolution Stay Protocol Washington,…
Request for Extension of Volcker Rule Conformance Period
SIFMA provides comments to the Board of Governors of the Federal Reserve System with preliminary data on the categories of…
Summary of the FSOC’s Conference on Asset Management
SIFMA's Asset Management Group (SIFMA AMG) and the Association of Institutional Investors submitted a letter to the U.S. Department of…
Potential Market Impact of the Net Stable Funding Ratio
SIFMA's Asset Management Group (SIFMA AMG), in a letter to the Basel Committee on Banking Supervision (BCBS), expressed substantial concerns…
Consultation Report titled “Good Practices on Reducing Reliance on CRAs in Asset Management”
SIFMA's Asset Management Group (SIFMA AMG) submitted comments to the International Organization of Securities Commissions (IOSCO) in response to a…
Amended Comments on the Netting of Swaps
SIFMA Asset Management Group (SIFMA AMG), Investment Adviser Association, the Investment Company Institute (ICI), and the Managed Funds Association (MFA),…
Rulemaking Related to Supervision and Regulation of Non SIFIs
SIFMA’s Assets Management Group (SIFMA AMG), the American Council of Life Insurers (ACLI), the American Financial Services Association (AFSA), the…
Dealing Commissions in MiFID II/MiFIR Consultation Paper
The Dealer Commissions Working Group of the the Asset Management Group of SIFMA (SIFMA AMG) provides comments to the European…
The Aggregation Proposal Relating to Position Limits
The Asset Management Group of SIFMA (SIFMA AMG) provides additional comments to the Commodity Futures Trading Commission (CFTC) on the Notice…
Questions in Consultation Paper on the Clearing Obligation under EMIR (no_1)
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the European Securities and Markets Authority (ESMA) on its consultation paper…
Questions in Consultation Paper on the Clearing Obligation under EMIR (no_2)
SIFMA's Asset Management Group (SIFMA AMG) provides comments to the European Securities and Markets Authority (ESMA) on its consultation paper…
Rule Proposal on Concentration Limits on Large Financial Companies
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Board of Governors of the Federal Reserve regarding…
JAC Alert on Margining of Accounts Held by the Same Beneficial Owner
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the CME Group in response to the Joint Audit…
SIFMA Guidance on Rule 506c Verification
In July 2013, the SEC amended Rule 506 of Regulation D under the Securities Act of 1933 to permit the…
Tax-Exempt Bond Joint Venture Structure under the Volcker Rule
SIFMA letter advising the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Office…
Swap Data Recordkeeping and Reporting Rules
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) in regards to the…
SIFMA Commends House Committee for Taking Action to Stop Eminent Domain Scheme
Release Date: May 21, 2014 Contact: Liz Pierce, 212.313.1173, [email protected] SIFMA Commends House Committee for Taking Action to Stop Eminent…
Consultation Document on FX Financial Instruments
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the European Commission’s (EC) in response to their Consultation…
Asset Managers Do Not Pose Systemic Risk
On Thursday, Jacob Lew, Treasury Secretary and head of the FSOC, will testify before the House Financial Services Committee to talk…
Separate Accounts Do Not Pose Systemic Risk
A SIFMA Asset Management Group (SIFMA AMG) survey of nine asset managers, with an aggregate AUM of $11.2 trillion, demonstrates…
Excluding Mortgage TBAs From the Definition of Derivative Contracts Under EMIR
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Conduct Authority (FCA) exclude mortgage TBAs from the…
Money Market Fund Reform and Adminests to Form PF
The Asset Management Group of SIFMA (SIFMA AMG) and the SIFMA Private Client Group provide comments to the Securities and…
Separate Accounts Do Not Pose Systemic Risk
This fact sheet highlights the results of a SIFMA AMG survey that shows separate accounts do not present systemic risk.…
Additional Comments on End-User Issues Resulting from the Dodd-Frank Act
The Asset Management Group of SIFMA (SIFMA AMG) provides additional comments to the Commodity Futures Trading Commission (CFTC) on CFTC…
CPO and CTA Capital Requirement and Customer Protection Measures
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the National Futures Association (NFA) on the NFA's Notice…
Assessment Methodologies for Identifying Non-Bank Non-Insurer G-SIFIs
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Stability Board (FSB) on the FSB's and…
Assessment Methodologies for Identifying Non-Bank Non-Insurer G-SIFIs
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Stability Board (FSB) on the FSB's and…
OFR Study in Regards to Separate Accounts
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Stability Board (FSB) and the Securities and…
Proposed Amendments to FINRA Rule 4210 for TBA Transactions
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Industry Regulatory Authority (FINRA) on proposed amendments…
Renewing Request for Relief from the CFTC’s Trade Execution Requirement Compliance Date
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) renewing a request…
The Aggregation of Position Limits
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the CFTC on the proposed rulemaking, Aggregation of Positions, RIN…
Regulatory Action and Position Limits
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC's…
Guidance Relating to Consent to Jurisdiction on SEFs
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity and Futures Trading Commission requesting Interpretive Guidance…
Kenneth E Bentsen, Jr on the Impact of the Volcker Rule on Jobs
SIFMA President and CEO Kenneth E Bentsen, Jr. testifies before the U.S. House Financial Services Committee on the impact of…
SIFMA Statement on TruPS CDOs Relief Under the Volcker Rule
Release Date: January 14, 2014 Contact: Katrina Cavalli, 212.313.1181, [email protected] SIFMA Statement on TruPS CDOs Relief Under the Volcker Rule…
Requesting Relief from the CFTC’s Trade Execution Requirement Compliance Date
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief…
SIFMA Statement on SEC Muni Advisor Guidance
Release Date: January 10, 2014 Contact: Liz Pierce, 212.313.1173, [email protected] SIFMA Statement on SEC Muni Advisor Guidance Washington, D.C., January…
Third Letter to US Federal Regulators on Ownership Interests in Connection with Certain CLO Debt Securities
SIFMA, the Loan Syndications and Trading Association (LSTA), the Structured Finance Industry Group (SFIG), and The Financial Services Roundtable (FSR)…
Requesting an Extension of the SEC’s Municipal Advisor Rule for SEC-Registered Investment Advisers
The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Adviser Association (IAA) provide comments to the Securities and…
Additional Comments on Ownership Interests in Connection with Certain CLO Debt Securities
SIFMA, the Loan Syndications and Trading Association (LSTA), the Structured Finance Industry Group (SFIG), and The Financial Services Roundtable (FSR)…
Ownership Interests in Connection with Certain CLO Debt Securities
SIFMA, the Loan Syndications and Trading Association (LSTA), the Structured Finance Industry Group (SFIG), the American Bankers Association (ABA), and…
Aggregation of Positions
The Asset Management Group of SIFMA (SIFMA AMG) and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to…
EMIR Reporting Obligation Application to Buy-Side
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the European Commission (EC) requesting a postponement of the…
SIFMA AMG and ISDA Announce that CUSIPs are Now Available for MAC Contracts
NEW YORK, December 12, 2013 - The Securities Industry and Financial Markets Association's (SIFMA) Asset Management Group (AMG) and the International…
Requesting Guidance and Relief on Regulations to Incorporate Swaps Records of Transactions
The Asset Management Group of SIFMA (SIFMA AMG) and the Managed Funds Association (MFA) provide comments to the Commodity Futures…
Javelin’s Made Available to Trade Determination
The Asset Management Group of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the Javelin SEF, LLC’s…
The Asset Management Industry
The asset management industry has a unique and different structure from the rest of the financial industry. It’s important to…
Asset Management and Financial Stability
The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Adviser Association (IAA) provide comments to the Securities and…
Multiple Federal Agencies on Credit Risk Retention
SIFMA, the American Bankers Association (ABA), the ABA Securities Association, and The Financial Services Roundtable (FSR) provide comments to the Office…
AMG on Credit Risk Retention
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Office of the Comptroller of the Currency (OCC),…
Straight-Through Processing, SEF Implementation and Relief in the Final Block Trade Rule
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) expressing significant concerns…
Supporting Legislation Modifying Section 716 of Dodd-Frank
SIFMA provides comments to the U.S. House of Representatives supporting H.R. 992, the Swaps Regulatory Improvement Act. Section 716 of…
Requesting Relief Relating to SEF Implementation and Swap Trade Execution
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting the CFTC:…
Money Market Fund Reform and Amendments to Form PF
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed new and amended rules and forms relating…
Requesting Relief from External Business Conduct Standards for Certain FX Transactions
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting the CFTC extend…
Requesting Interpretive Guidance Relating to Certain Foreign Exchange Transactions
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting interpretive guidance with…
The CFTC Cross-Border Phase-In Exemptive Order and Final Interpretive Guidance
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC's…
Applicability of CPO Amendments to Operators of Fund of Funds
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on application of…
Requesting Relief to the Aggregation Provision in Final Block Trade Rule
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting relief from…
Opposing the Use of Eminent Domain to Acquire and Refinance Underwater Mortgage Loans
SIFMA and 11 associations* provide comments to the US Congress strongly opposing proposals being consider by some U.S. municipalities to…
Deloitte-CFTC and EU OTC Derivatives Regulation: An Outcomes-Based Comparison
Deloitte MCS Limited was jointly commissioned by the Securities Industry and Financial Markets Association (SIFMA) and the Association for Financial…
Residential Real Estate Mortgage Foreclosure Process and Protections
SIFMA provides comments to the Uniform Law Commission (the Commission) pertaining to the Commission’s discussion draft, Residential Real Estate Mortgage Foreclosure Process…
Compliance With Certain Swap Regulations & US Person Definition
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) expressing its ongoing concerns regarding…
Requesting Relief Relating to Certain Foreign Exchange Transactions
The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide comments to the Commodity Futures…
LSOC Implementation and Clearing Mandate
The Asset Management Group of SIFMA (SIFMA AMG), the Investment Company Institute (ICI), and the Investment Adviser Association (IAA) provide…
Requesting Time Extension for Clearing Member Risk Management Requirements
The Asset Management Group of SIFMA (SIFMA AMG),the Futures Industry Association (FIA), Investment Company Institute (ICI) and Managed Funds Association…
Requesting Relief from the Minimum Liquidation Time for Non-Commodity Swaps
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting the CFTC take…
Opposing the Use of Eminent Domain in Pomona, CA
SIFMA and 21 associations provide comments to the Mayor and City Council of Pomona, California strongly opposing any proposal that…
Opposing the Use of Eminent Domain in San Joaquin, CA
SIFMA and 21 associations provide comments to the Mayor and City Council of San Joaquin, California strongly opposing any proposal…
Opposing the Use of Eminent Domain in La Puente, CA
SIFMA and 21 associations provide comments to the Mayor and City Council of La Puente, California strongly opposing any proposal…
Opposing the Use of Eminent Domain in Orange Cove, CA
SIFMA and 21 associations provide comments to the Mayor and City Council of Orange Cove, California strongly opposing any proposal…
Opposing the Use of Eminent Domain in El Monte, CA
SIFMA and 21 associations provide comments to the Mayor and City Council of El Monte, California strongly opposing any proposal…
Requesting Relief from External Business Conduct Rules
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting the CFTC…
SIFMA Asset Management Group Helps Develop New Market Agreed Coupon for Interest Rate Swaps
New York, NY, April 23, 2013 — SIFMA today announced that SIFMA’s Asset Management Group (AMG), working in collaboration with the…
Use of Eminent Domain to Acquire Underwater Mortgages in North Las Vegas, NV
SIFMA and 20 other associations provide comments to the Mayor and City Council of North Las Vegas, Nevada opposing a…
Use of Eminent Domain to Acquire Underwater Mortgages in Richmond, CA
SIFMA and 22 other associations provide comments to the Mayor and City Council of Richmond, California opposing a proposal involving…
Kenneth E. Bentsen, Jr. on Legislation Regarding Derivatives
SIFMA Acting President & CEO Kenneth E. Bentsen, Jr. testifies before the U.S. House Financial Services Subcommittee on Capital Markets…
Supporting the Cyber Intelligence Sharing and Protection Act
SIFMA, along with the American Bankers Association (ABA), The Clearing House (TCH), the Consumer Bankers Association (CBA), the Electronic Funds Transfer Association, The Financial…
Requesting No-Action Relief Regarding Application of Certain Reporting Obligations
The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide comments to the Commodity Futures…
NFA Compliance Rule 2-46
The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Company Institute (ICI) provide confirmation to the National Futures…
Requesting No-Action Relief Extending Compliance Date 3 Reporting Obligations
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting that the…
Greenberg Traurig: Memorandum on Brockton, MA Eminent Domain Takings of Mortgage Debt
SIFMA requested the firm of Greenberg Traurig review the authority of the City of Brockton under Massachusetts statutory law and the Massachusetts…
Margin Requirements for Non-Centrally-Cleared Derivatives
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Basel Commission on Banking Supervision (BCBS) and the Board of…
Discouraging the Use of Eminent Domain in Richmond, California
SIFMA and the SIFMA Asset Management Group provide comments to the Mayor and City Council Members of Richmond, California discouraging…
Discouraging the Use of Eminent Domain in El Monte, CA
SIFMA and the SIFMA Asset Management Group provide comments to the Mayor and City Council Members of El Monte, California discouraging the…
Discouraging the Use of Eminent Domain in La Puente, CA
SIFMA and the SIFMA Asset Management Group provide comments to the Mayor and City Council Members of La Puente, California discouraging the use eminent…
Discouraging the Use of Eminent Domain in North Las Vegas, NV
SIFMA and the SIFMA Asset Management Group provide comments to the Mayor and City Council Members of North Las Vegas, Nevada discouraging the…
Requesting No-Action Relief with Respect to the Clearing Requirement for iTraxx CDS Indices
The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief in…
Capital, Margin and Segregation Requirements for SBSDs and MSBSPs
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed capital, margin and…
Enhancing Customer Protection
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed rulemaking, which…
Guidance Regarding Compliance with Certain Swap Regulations
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on further proposed guidance…
The Netting of Swaps
SIFMA's Asset Management Group (AMG), Investment Adviser Association, the Investment Company Institute (ICI), and the Managed Funds Association (MFA) provide…
Recommendations for Money Market Fund Reform
SIFMA provides comments to the Financial Stability Oversight Council (FSOC) on the proposed recommendations regarding money market mutual fund reform …
The FSB’s Consultative Document Related to Policy Recommendations for Money Market Funds
SIFMA provides comments to the Financial Stability Board (FSB) on FSB's Consultative Document An Integrated Overview of Policy Recommendations dated 18 November…
Plans to Study the Use of Eminent Domain to Seize Troubled Mortgages
SIFMA and SIFMA's Asset Management Group (AMG) provide follow-up comments the Brockton, Mass. City Council opposing the use of eminent domain…
Opposing the Use of Eminent Domain to Seize Mortgage Loans in Salinas, CA
SIFMA provides comments to the Mayor of Salinas, CA opposing the Salinas City Council's agreement with a third party to explore…
Opposing the Use of Eminent Domain to Seize Mortgage Loans in Brockton, MA
SIFMA provides comments to the Brockton, MA City Council cautioning against the idea of using eminent domain to seize mortgage loans from…
Requesting Relief from External Business Conduct Requirements and Other Rules
SIFMA's Asset Management Group (AMG) provides comments to the Commodity Futures Trading Commission (CFTC) supporting the International Swaps and Derivatives…
Temporary Exclusion for Investments in Securitizations
SIFMA, Investment Adviser Association (IIA), Investment Company Institute (ICI) and the Managed Funds Association (MFA) provide comments to the Commodity…
Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
SIFMA's Asset Management Group (AMG) provides comments to multiple regulators on margin requirements for uncleared swaps for swap dealers and…
FX Forwards and FX Swaps Treasury Determination
SIFMA's Asset Management Group (AMG), Investment Company Institute (ICI), the Managed Funds Association (MFA) and Investment Adviser Association provide comments…
CFTC Registrations Based on the Inclusion of FX Forwards and Swaps
SIFMA's Asset Management Group (AMG), Investment Company Institute (ICI), the Managed Funds Association (MFA) and Investment Adviser Association provide comments…
Proposed Clearing Determination Under Section 2(h) of the CEA
SIFMA's Asset Management Group (AMG) provides comments to the Commodity Futures Trading Commission (CFTC) expressing concerns with regards to the…
The Use of Eminent Domain to Restructure Performing Loans
SIFMA and 25 other associations provide comments to the Federal Housing Finance Agency (FHFA) on the use of eminent domain to…
Proposed Guidance for Cross-Border Application of Certain Swap Provisions of CEA
SIFMA's Asset Management Group (AMG) provides comments to the Commodity Futures Trading Commission (CFTC) on proposed interpretive guidance on the cross-border…
The Use of Eminent Domain to Restructure Performing Loans
SIFMA provides comments to the Federal Deposit Insurance Corporation (FDIC) on the use of eminent domain to restructure performing loans. SIFMA shares…
The Use of Eminent Domain to Restructure Performing Loans
SIFMA provides comments to the U.S. Department of Treasury (Treasury) on the use of eminent domain to restructure performing loans. SIFMA…
The PWG’s Report on Money Market Fund Reform
SIFMA and 12 other associations provide comments to the Securities and Exchange Commission (SEC) on the President’s Working Group (PWG's) report…
Timothy W. Cameron, Esq. on Eminent Domain Proposal, San Bernardino, CA
Statement of Timothy W. Cameron, Esq., Managing Director of the SIFMA Asset Managers Group, before the Joint Powers Authority (JPA) of San…
Timothy W. Cameron, Esq. on Eminent Domain Proposal
Statement of Timothy W. Cameron, Esq., Managing Director of the SIFMA Asset Managers Group, before the Joint Committee on Finance,…
Proposed Use of Eminent Domain by California Municipalities to Seize Mortgage Loans Held in MBS
SIFMA provides comments to the Board of Governors of the Federal Reserve System, and the U.S. Departments of Treasury and…
A Legal Analysis of the Eminent Domain Proposal
SIFMA provides comments and a legal analysis performed by O’Melveny & Myers to the California Homeownership Protection Program Joint Powers Authority (JPA) on an…
A Legal Analysis of the Eminent Domain Proposal in Ontario, CA
SIFMA provides comments and a legal analysis performed by O’Melveny & Myers to the City Council of Ontario California on an eminent…
A Legal Analysis of the Eminent Domain Proposal in San Bernardino, CA
SIFMA provides comments and a legal analysis performed by O’Melveny & Myers to the San Bernardino County California Board of Supervisors on an…
A Legal Analysis of the Eminent Domain Proposal in Fontana, CA
SIFMA provides comments and a legal analysis performed by O’Melveny & Myers to the City Council of Fontana California on an eminent domain proposal. …
Timothy W. Cameron, Esq. before a Special Meeting of the California Join Powers Authority
Statement of Timothy W. Cameron, Esq. Managing Director, SIFMA Asset Managers Group during a special meeting of the Homeownership Protection Program…
The Joint Powers Agreement of the Homeownership Protection Plan in San Bernardino County, CA
SIFMA and 17 other organizations provide comments to the San Bernardino County Board of Supervisors strongly objecting to the Joint…
Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed procedures to establish…
An Amendment Offered to the Commodity Pool Operator Exemption
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting an extension of time…
Registered Investment Companies Registering as Commodity Pool Investors
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on CFTC’s proposed amendments to…
SIFMA AMG on Proposed Process to Make Swaps Available to Trade
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the proposed process…
Provisions of the Volcker Rule Relating to Proprietary Trading
The Asset Management Group (AMG) of SIFMA provides comments to multiple federal regulators on the proposed restrictions on proprietary trading (the…
Proprietary Trading Provisions of the Volcker Rule
SIFMA, The Clearing House (TCH), The Financial Services Roundtable (FSR), and the American Bankers Association (ABA) provide comments to multiple federal…
Testimony before a Joint-US House Subcommittee Hearing on the Volcker Rule
Testimony of Douglass Peebles, chief investment officer and head of fixed income, AllianceBernstein, on behalf of SIFMA, before a joint U.S.…
The SEC’s Concept Release on the Use of Derivatives by Investment Companies
SIFMA Asset Management Group (AMG) provides comments to the Securities and Exchange Commission (SEC) on the SEC's Concept Release: Use…
Requirements for Shelf Registration of Asset-Backed Securities
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on the re-proposed registration and transaction…
Shelf Eligibility Conditions for Asset-Backed Securities
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the re-proposal of shelf eligibility conditions for asset-backed securities, Release…
Customer Clearing Documentation
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposed rule relating…
The Study of Stable Value Contracts
The Asset Management Group of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange…
Eligible Contract Participants and Other Related Definitions
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and…
The Report of Foreign Bank and Financial Account
SIFMA's Asset Management Group (AMG) provides additional comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of…
Business Conduct Standards for Security-Based Swaps Dealers and Major Security-Based Swap Participants
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on business conduct standards for security-based…
Standards for Security-Based Swap Dealers & Major Security-Based Swap Participants
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Securities…
Proposals Relating to the Protection of Cleared Swaps Customer Contracts & Collateral
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposals related to the protection…
The Registration & Compliance Regime for Commodity Pool Operators & Commodity Trading Advisers
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC's February 11, 2011…
Proposed Rule to Disqualify Felons & Bad Actors From Securities Offerings
SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposal disqualify felons and bad actors from securities…
Proposals Related to Margin Requirements for Uncleared Swaps
The Asset Management Group (AMG) of SIFMA provides comments to multiple federal regulators including the Commodity Futures Trading Commission (CFTC),…
Proposed Dealer and Major Participant Definitions
The Asset Management Group (AMG) of SIFMA provides supplemental comments to the Commodity Futures Trading Commission (CFTC) and the Securities…
Proposed Position Limits for Derivatives
The Asset Management Group (AMG) of SIFMA provides supplemental comments to the Commodity Futures Trading Commission (CFTC) on a Notice of…
Foreign Bank and Financial Accounts
SIFMA's Asset Mangement Group (AMG) provides comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department on…
Proposed Agency Debt and Agency MBS Fails Charge Trading Practice
SIFMA provides comments to the Treasury Market Practices Group (TMPG) on Draft Recommended Agency Mortgage-Backed Securities and Agency Debt Securities…
Proposed Rules for Credit Risk Retention
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission, the Treasury Department, the Board…
Risk Management Requirements for Derivatives Clearing Organizations
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed risk management requirements…
Implementing the Private Funds Portion of the Volcker Rule
The Asset Management Group (AMG) of SIFMA provides supplemental comments to the U.S. Department of the Treasury, the Federal Deposit Insurance Corporation (FDIC), the…
Certain References to Ratings in Their Regulations
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed amendments to Rule…
Implementing the Private Funds Portion of the Volcker Rule
The Asset Management Group (AMG) of SIFMA provides comments to U.S. Department of the Treasury, the Federal Deposit Insurance Corporation…
Reporting by Investment Advisers on Form PF
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) and the Commodity Futures…
Commodity Pool Operators and Commodity Trading Advisors
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed amendments to…
Registration and Regulation of Security-Based Swap Execution Facilities
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on the registration and…
Improvements in the Infrastructure for OTC Derivatives
The managements of the derivatives industry participants: the Asset Management Group (AMG) of SIFMA, AllianceBernstein, Bank of America-Merrill Lynch, Barclays…
Position Limits for Derivatives
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposed rule on…
Swap Execution Facilities
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange…
Proposed Rule on Confirmation, Portfolio Recognition, and Portfolio Compression Requirements
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposed rule to establish confirmation,…
Business Conduct Standards for Swap Dealers and Major Swap Participants, Particularly Special Entities
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed business conduct standards for swap…
Further Definition of Major Swap Participants
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and…
Proposed Rules for Reporting of Swap Data
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed rules for reporting of…
Protection of Collateral of Counterparties to Uncleared Swaps
The Asset Management Group (AMG) of SIFMA provides comments in response to the Notice of Proposed Rulemaking, issued on December 3, 2010…
Protection of Cleared Swaps Customers Before & After Commodity Broker Bankruptcies
SIFMA provides comment to the Commodity Futures Trading Commission (CFTC) on the Protection of Cleared Swaps Customers Before and After…
Deadlines for Major Swap Participants Regulation Proposals
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on deadlines for major swap participants…
Protection of Cleared Swaps Customers Before and After Commodity Broker Bankruptcies
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on a proposal relating to the…
Proposed Regulation SBSR Under the Securities Exchange Act of 1934
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on certain aspects of proposed…
3 Way Trade Confirmation & Settlement Window
The Asset Managers Forum of SIFMA and the SIFMA Government Operations Committee provide comments to the Operational Arrangements Working Group…
Money Market Reforms in the President’s Working Group Report
The Asset Management Group (AMG) of SIFMA provides comments to the Securities and Exchange Commission (SEC) on the options for…
Determination of Major Swap Participant
The Asset Management Group (AMG) of SIFMA provides additional comments to the Commodity Futures Trading Commission (CFTC) and the Securities and…
Derivatives Trade Execution and Related Reporting Requirements
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange…
Position Limits Under Section 737 of the Dodd-Frank Act
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in advance of the issuance…
Consolidated Financial Statements
SIFMA's Asset Management Group Accounting Committee provides comments to the Financial Accounting Standards Board (FASB) requesting participation in FASB Public Roundtable Meetings regarding Consolidated Financial…
Key Definitions in the Derivatives Title of the Dodd-Frank Act
The Asset Management Group (AMG) of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and…
FASB Report: Exposure Draft, Proposed Accounting Standards Update, Contingencies
SIFMA provides comments to the Financial Accounting Standards Board on its report: Exposure Draft, Proposed Accounting Standards Update, Contingencies, (Topic 450),…
Asset-Backed Securities
SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed rule relating to asset-backed securities (ABS), Release…
Consultation Report on Hedge Funds Oversight
SIFMA's Prime Brokerage Committee provides comments to the International Organization of Securities Commissions (IOSCO) on the Consultation Report on Hedge Funds Oversight. Comments…
T. Timothy Ryan, Jr. on Regulating Systemic Risk
Testimony of T. Timothy Ryan, Jr., President & CEO, SIFMA before the US House Financial Services Committee for the hearing,…
Cross-Trading Policies and Procedures
SIFMA provides comments to the Employee Benefit Security Administration (EBSA) of the U.S. Department of Labor (DOL) on cross-trading policies and procedures…
The National Employee Savings and Trust Guarantee
The Asset Managers Forum (AMF) of The Bond Market Association (TBMA)* provides comments to U.S. Senators Mike Crapo (R-Idaho) and…
The Pensions Protection Act
The Asset Managers Forum (AMF) of The Bond Market Association (TBMA)* provides comments to the U.S. House Education and the Workforce Committee…
Additional Mark-Up Policy for Transactions in Some Debt Securities
The Senior Executives Group (SEG) of the Assets Managers Forum (AMF) of The Bond Market Association (TBMA)* provides comments to…