Proposed Capital Substituted Compliance for EU Nonbank Swap Dealers (SIFMA, ISDA and IIB)
SIFMA, ISDA and IIB provided supplemental comments to the Commodity Futures Trading Commission (CFTC) on the proposed Order and Request…
Real-Time Public Reporting Requirements and Swap Data Recordkeeping and Reporting Requirements (SIFMA and ISDA)
SIFMA and The International Swaps and Derivatives Association, Inc. (ISDA) provided comments to the Commodity Futures Trading Commission (CFTC) on…
Regulatory Capital Rule: Amendments Applicable to Large Banking Organizations and To Banking Organizations With Significant Trading Activity (SIFMA and ISDA)
SIFMA and The International Swaps and Derivatives Association (ISDA) provided further comments to the Federal Reserve System, the Federal Deposit…
Operational Resilience Framework for Futures Commission Merchants, Swap Dealers and Major Swap Participants (SIFMA and IIB)
SIFMA and the Institute of International Bankers (IIB) provided comments to the Commodity Futures Trading Commission (CFTC) on their rule proposal…
Substituted Compliance for Nonbank Swap Dealers Subject to UK PRA Capital and Financial Reporting Requirements (SIFMA, IIB, and ISDA)
SIFMA, The Institute of International Bankers (IIB), and The International Swaps and Derivatives Association (ISDA) provided comments to the Commodity…
Capital Requirements for Swap Dealers and Major Swap Participants (SIFMA, IIB, and ISDA)
SIFMA, The Institute of International Bankers (IIB), and the International Swaps and Derivatives Association (ISDA), provided comments to the Commodity…
Notice of Proposed Rulemaking Regarding Operational Resilience Framework for Futures Commission Merchants, Swap Dealers, and Major Swap Participants (Joint Trades)
SIFMA, The Futures Industry Association (FIA), the Institute of International Bankers (IIB), and the International Swaps and Derivatives Association (ISDA)…
Supplemental Comments on Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report
SIFMA provided supplemental comments to their prior comment letter on the Electronic Submission of Certain Materials Under the Securities Exchange…
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)…
ANPRM on Potential Amendments to the Risk Management Program (SIFMA and ISDA)
SIFMA and the International Swaps and Derivatives Association (ISDA) provided comments to the Commodity Futures Trading Commission (CFTC) on its…
Comments on Proposed Capital Substituted Compliance for EU Nonbank Swap Dealers (SIFMA, ISDA and IIB)
SIFMA, ISDA and IIB provided comments to the CFTC on the proposed Order and Request for Comment on an Application…
Reopening of Comment Period for Proposed Position Reporting for Large SBS Positions (10B-1) (SIFMA, ISDA and IIB)
SIFMA, ISDA and IIB provided comments to the SEC on the reopening of its Position Reporting for Large SBS Positions…
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…
Comments on proposed Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934 and FOCUS Amendments
SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) on Electronic Submission of Certain Materials Under the Securities…
Comments on proposed Capital Substituted Compliance for Mexican Nonbank Swap Dealers (SIFMA and ISDA)
SIFMA and ISDA provided comments to the CFTC on the proposed Order and Request for Comment on an Application for…
Public Disclosure of Security-Based Swaps Positions
In this post, SIFMA's Kyle Brandon explains why, to avoid potential disruption to the legitimate uses of SBS for supporting capital…
Request for Comment on an Application for a Capital Comparability Determination From the Financial Services Agency of Japan (SIFMA, IIB and ISDA)
SIFMA, The Institute of International Bankers (IIB) and International Swaps and Derivatives Association (ISDA) provided comments to the Commodity Futures…
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)…
Comments on the SEC’s SBS Execution Facility Proposal (SIFMA and ISDA)
SIFMA and ISDA provided comments to the SEC on proposed Rules Relating to Security-Based Swap Execution and Registration and Regulation…
Comments on Proposed Amendments to SEC Beneficial Ownership Reporting Requirements
SIFMA provided comments to the SEC's proposed amendments of Beneficial Ownership Reporting requirements. See Also: SIFMA AMG on SEC Proposed…
Comments on the SEC’s proposed Prohibition Against Undue Influence over Chief Compliance Officers rule (SIFMA, IIB, and ISDA)
SIFMA, IIB and ISDA provided comments to the SEC on protections for chief compliance officers against coersion, manipulation, misleading or…
Comments on the proposed Position Reporting of Large Security-Based Swap Positions requirements (SIFMA, IIB, and ISDA)
SIFMA, IIB, and ISDA provided comments to the SEC's proposed security-based swap position reporting requirements.
Comments on the Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps Proposal (SIFMA, IIB, and ISDA)
SIFMA, IIB, and ISDA provided comments to the SEC on the proposed security-based swap anti- fraud and anti-manipulation rule (Rule…
Substituted Compliance for the Federal Republic of Germany
SIFMA provided comments to the Securities and Exchange Commission (“SEC” or “Commission”) regarding (a) the application submitted by the Bundesanstalt…
FINRA Security-Based Swaps Proposal
SIFMA provided comments to the SEC in response to the above-captioned release by the Financial Industry Regulatory Authority, Inc. (“FINRA”)…
Security-Based Swap Dealers Substituted Compliance for UK
SIFMA provided comments to the SEC regarding the substituted compliance application submitted by the United Kingdom (“UK”) Financial Conduct Authority…
Security-Based Swap Dealers Substituted Compliance for France
SIFMA provided comments to the SEC in response to reopening the comment period for the Commission’s 2020 proposed conditional substituted…
SEC Proposed French Substituted Compliance Order
SIFMA provided comments to the SEC regarding the substituted compliance application submitted by the French Autorité des Marchés Financiers (“AMF”)…
SEC Security-Based Swap Germany Substituted Compliance Order
SIFMA provided comments to the SEC regarding the substituted compliance application submitted by the Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”) in connection…
Joint Trades on Portfolio Margining of Uncleared Swaps and NonCleared Security-Based Swaps
SIFMA and ISDA provided comments to the U.S. Commodity Futures Trading Commission (the “CFTC”) and the U.S. Securities and Exchange…
Joint Trades on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
SIFMA and joint trades provided comments to the CFTC on the Notices of Proposed Rulemaking in respect of the Margin…
Supplemental Submission on “SBS as Securities”
SIFMA provided comments to the SEC to supplement our previous submissions regarding the Commission’s Order Extending Temporary Exemptions under the…
Joint Trades on COVID-19 Extension Request
SIFMA and joint trades provided comments to the U.S. Commodity Futures Trading Commission, pursuant to Commission Rule 140.99 and on…
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…
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…
CFTC Open Meeting
Commodity Futures Trading Commission Open Meeting Thursday, June 4, 2020 Opening Statements Chairman Heath P. Tarbert In his opening statement,…
Joint Trades Request for Extension of Certain Covid-19 No-Action Regulatory Relief
SIFMA and joint trades provided comments to the Divisions, that they extend through midnight on September 30, 2020, the previously-granted…
CFTC Open Meeting
Commodity Futures Trading Commission Open Meeting Thursday, May 28, 2020 Opening Statements Chairman Heath P. Tarbert In his opening statement,…
Joint Trades on Amendments to Part 43, 45 and 49 Reporting
SIFMA and ISDA provided comments to the CFTC in response to the proposed amendments to the CFTC’s swap data reporting…
Joint Trades on Real-Time Public Reporting Requirements (Block Thresholds)
SIFMA and ISDA provided comments to the CFTC on the proposed revisions to the real-time public reporting requirements published in…
CFTC Global Markets Advisory Committee Meeting
Commodity Futures Trading Commission Global Markets Advisory Committee Meeting Tuesday, May 19, 2020 Opening Statements Commissioner Dawn D. Stump In…
CFTC Energy and Environmental Markets Advisory Committee Meeting
Commodity Futures Trading Commission Energy and Environmental Markets Advisory Committee Meeting Thursday, May 7, 2020 Opening Statements Chairman Heath P.…
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…
CFTC Open Meeting
Commodity Futures Trading Commission Open Meeting Tuesday, April 14, 2020 Key Topics & Takeaways The Commission unanimously approved all five…
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…
Cross-Border Application of the Registration Thresholds and Certain Requirements Applicable to SDs and MSPs
SIFMA and the Institute of International Bankers (IIB) provided comments to the Commodity Futures Trading Commission (CFTC) on their proposal…
Joint Trades Capital Requirements for Swap Dealers and Major Swap Participants
SIFMA and joint trades provided the Commodity Futures Trading Commission with comments in response to Capital Requirements for Swap Dealers and…
Post-Trade Name Give-Up on Swap Execution Facilities
SIFMA provided comments to Commodity Futures Trading Commission (CFTC) on their Post-Trade Name Give Up on Swap Execution Facilities Proposal.
Security-Based-Swaps Follow-Up Exemption Request Letter
SIFMA provided additional comments to the SEC regarding our submission dated December 20, 2018 on the Commission’s Order Extending Until February…
Joint Letter on Proposed Amendments to Uncleared Margin Requirements
SIFMA and The Institute of International Bankers provided comments to the Commodity Futures Trading Commission’s proposal to amend Margin Requirements…
Commodity Futures Trading Commission Open Meeting
Commodity Futures Trading Commission Open Meeting Wednesday, December 18, 2019 Key Topics & Takeaways Cross-Border: In a 3-2 vote, the…
Margin and Capital Requirements for Covered Swap Entities
SIFMA and joint trades provided comments to multiple agencies in response to proposed amendments and request for comment on Margin…
Commodity Futures Trading Commission Open Meeting
Commodity Futures Trading Commission Open Meeting Monday, November 25, 2019 Opening Statements & Introduction Chairman Heath P. Tarbert After providing…
Federal Deposit Insurance Corporation Open Meeting on SA-CCR
Federal Deposit Insurance Corporation Board of Directors Open Meeting Tuesday, November 19, 2019 Key Topics & Takeaways The FDIC Board…
Non-U.S. CCP Rule Proposals (RIN 3038-AE87 and RIN 3038-AE65)
SIFMA provided comments to the Commodity Futures Trading Commission (CFTC) on proposals to allow certain non-U.S. clearing organizations that do…
Commodity Futures Trading Commission Open Meeting
Commodity Futures Trading Commission Open Meeting Tuesday, November 5, 2019 Opening Statements & Introduction Chairman Heath P. Tarbert After providing…
House Agriculture Committee Meeting on CFTC Reauthorization
House Agriculture Committee “Business Meeting – Reauthorization of the Commodity Futures Trading Commission” Wednesday, October 30, 2019 Bills Considered H.R.…
Commodity Futures Trading Commission Open Meeting
Commodity Futures Trading Commission Open Meeting Wednesday, October 16, 2019 Key Topics & Takeaways Presentation 1: Proposed Rule – Amendment…
Extension Request for Certain Swap Data Repository and Data Reporting Requirements
SIFMA and ISDA sent comments to the U.S. Commodity Futures Trading Commission regarding another extension to comment period for the…
SIFMA Statement on FDIC NPR on Swap Margin Requirements
Washington, D.C., September 17, 2019 – SIFMA today issued the following statement from President and CEO Kenneth E. Bentsen, Jr.…
Federal Deposit Insurance Corporation Open Meeting on Inter-Affiliate Initial Margin Requirements
Federal Deposit Insurance Corporation Board of Directors Open Meeting Tuesday, September 17, 2019 Key Topics & Takeaways Swap Margin NPR…
Request for Extension of Cross Border Clearing Comment Deadlines
SIFMA, FIA, ICE and MFA wrote to the CFTC to request a 60 extension of the comment periods for the…
Joint Letter on Posting Cash and Money Market Funds for Initial Margin
SIFMA, ISDA, MFA, ICI, IMMFA, SIFMA AMG sent comments to the CFTC, OCC, FRB requesting US regulators provide relief or…
Joint Trades on SEC Proposed Amendments and Guidance to Cross-Border Rule
SIFMA and The Institute of International Bankers sent comments to the SEC on the Proposed Rule Amendments and Guidance Addressing…
SIFMA Statement on SEC’s Adoption of Capital, Margin and Segregation Requirements for Security-Based Swap Dealers
Washington, D.C., June 21, 2019 – SIFMA today issued the following statement from Kenneth E. Bentsen, Jr., SIFMA President and…
Swap Data Repository and Data Reporting Requirements
SIFMA and ISDA is requesting that the U.S. Commodity Futures Trading Commission extend the comment period for the Proposed Amendments to the…
Uncleared Swap Margin Requirements
SIFMA, SIFMA AMG, ISDA, and GFXD together are requesting that U.S. regulators provide clarification that covered swap entities and their…
Margin Requirements for Non-Centrally Cleared Derivatives – Initial Margin Models
SIFMA, SIFMA AMG, International Swaps and Derivatives Association, Inc. (ISDA) and Association of the Luxembourg Fund Industry (ALFI) provide comments…
Inter-Affiliate Initial Margin Requirements
SIFMA along with the American Bankers Association (ABA), ABA Securities Association, Bank Policy Institute (BPI), U.S. Chamber’s Center for Capital Markets Competitiveness’s (CCMC),…
Risk Mitigation Techniques for Uncleared Security-Based Swaps
SIFMA and ISDA provide comments to the Securities and Exchange Commission (SEC) on its proposed rules for risk mitigation techniques…
Margin Requirements for Non-Centrally Cleared Derivatives – Final Stage of Initial Margin Phase-In
SIFMA along with the Global Foreign Exchange Division of the Global Financial Markets Association, the American Bankers Association and the…
Post-Trade Name Give-Up on Swap Execution Facilities
SIFMA provided comments to the Commodity Futures Trading Commission relating to post-trade name give-up (“PTNGU”) on swap execution facilities (“SEFs”). Although…
Swap Execution Facilities and Trade Execution Requirement
SIFMA welcomes the opportunity to provide the Commodity Futures Trading Commission with comments on the proposal to amend the Commission’s…
Request to Extend Certain Temporary Exemptions to the Treatment of SBS under the Exchange Act
This letter responds to the request by staff of the U.S. Securities and Exchange Commission (the “Commission”) that SIFMA supplement…
Reopening of Comment Periods for Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers
SIFMA provides comments to the Securities and Exchange Commission (SEC) in response to re-opening the comment period for the SEC’s…
Proposed Guidance and Exemptions to Clarify Treatment of Security-Based Swaps Under the Exchange Act
SIFMA proposed guidance and exemptions relating to the treatment of security-based swaps (“SBS”) as “securities” under the Securities Exchange Act…
Reopening of Comment Periods for Capital, Margin, and Segregation Requirements
SIFMA and Institute of International Bankers (IIB) provided comments to the Securities and Exchange Commission (SEC) to extend the deadline…
Proposed Exemption from DCO Registration
SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on the Notice of…
Proposed DCO Registration Exemption; Extension Request
SIFMA sent comments to the CFTC on its proposed rule regarding exemptions from derivatives clearing organization registration. SIFMA appreciates the…
Segregation of Assets Held as Collateral in Uncleared Swap Transactions
SIFMA and ISDA appreciate the opportunity to provide the Commodity Futures Trading Commission ("CFTC" or "the Commission") with comments on its proposed…
Margin Requirements for Non-Centrally Cleared Derivatives
SIFMA and other associations submitted a letter to BCBS-IOSCO, global regulators and other standard setters on the logistical and further…
De Minimis Exception to the Swap Dealer Definition
SIFMA and ISDA provided comments to the CFTC on the Notice of Proposed Rulemaking regarding the De Minimis Exception to the…
Initial Margin for Non-Centrally Cleared Derivatives: Issues for 2019 and 2020
In response to the global financial crisis of 2008-2009, the G20 agreed to a financial regulatory reform agenda covering the…
SEC-CFTC Harmonization: Key Issues under Title VII of the Dodd-Frank Act
The matrix below summarizes key issues raised as a result of differences between the rules adopted or proposed by the…
SIFMA Testimony on Legislative Proposals Regarding Derivatives
Kenneth E. Bentsen, Jr., President & CEO of SIFMA, testified before the U.S. House of Representatives Committee on Financial Services…
SIFMA Submits Request to the SEC to extend relief from the Application of Federal Securities Laws to Security-Based Swaps
On January 12, SIFMA submitted a request to the SEC seeking an extension of its Interim Final Rules (RIN 3235-AL17;…
Non-US Trading Platform and CCP White Paper
The increase in multilateral trading and central clearing of swaps markets since Congress enacted the Dodd-Frank Act increases the need…
Project KISS Initiative in Regards to Swap Dealer Registration
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in response to their Project KISS initiative (RIN 3038-AE55) covering…
Project KISS Initiative in Regards to the Treatment of Inter-Affiliate Swap Transactions
SIFMA provides comments in response to the Commodity Futures Trading Commission's (CFTC) Project KISS initiative (RIN 3038-AE55) covering the Commission’s application…
Project KISS Initiative in Regards to Segregation of Independent Amount Requirements
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in response to their Project KISS initiative (RIN 3038-AE55) covering the…
Project KISS Initiative in Regards to Risk Management Program Requirements
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in response to their Project KISS initiative (RIN 3038-AE55) covering…
CFTC’s KISS Initiative in Regards to External Business Conduct Requirements
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in response to their Request for Public Input on Simplifying…
CFTC Request for Information: Project KISS – Recordkeeping (RIN 3038-AE55)
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on their Request for Information (RFI) as a part of…
Project KISS Initiative in Regards to Extension of Certain Time-Limited No-Action Relief
SIFMA, IIB and ISDA submitted comments in response to the CFTC’s Project KISS initiative (RIN 3038-AE55) covering the extension of…
CCO Duties and Annual Report Requirements for Futures Commission Merchants, Swap Dealers, and Major Swap Participants
SIFMA and the Futures Industry Association (FIA) provided comments to the Commodity Futures Trading Commission (CFTC) regarding chief compliance officer…
The CFTC’s Reproposed Capital Requirements for Swap Dealers and Major Swap Participants
SIFMA provided comments to the Commodity Futures Trading Commission (CFTC) on the Commission’s reproposed capital and liquidity requirements, and related…
Proposal to Amend Rule 1.31 of the CEA: Recordkeeping
SIFMA provided comments to the Commodity Futures Trading Commission (CFTC) on Recordkeeping. SIFMA supports the Proposal and urges the Commission…
Position Limits for Derivatives
SIFMA AMG, Managed Funds Association (MFA) and Alternative Investment Management Association (AIMA) provided comments to the Commodity Futures Trading Commission…
Request for Relief from Application of Rules to SBS as Securities
SIFMA sent comments to the SEC regarding the implications of Sections 761 and 768 of the Dodd-Frank Wall Street Reform…
The 1934 Act and FINRA Rule 0180
SIFMA provided comment to the Securities and Exchange Commission (SEC) supporting extensions of temporary relief regarding the treatment of SBS…
SIFMA and IIB on CFTC’s Proposed Rules on Cross Border Application
SIFMA and the Institute of International Bankers (IIB) provided comments to the Commodity Futures Trading Commission (CFTC) on the Commission’s…
CFTC’s Proposed Rules on Cross Border Application
SIFMA and other associations provided comments to the Commodity Futures Trading Commission (CFTC) on the Commission’s proposed rules regarding the…
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…
The Extension on the QCCP Transitional Relief
SIFMA provided comments to the European Commission on the extension on the QCCP transitional relief. SIFMA and its members support…
CCO Annual Report Requirements for FCMs, SDs and Major Swap Participants; Amendments to Filing Date
SIFMA, FIA, and ISDA are pleased to submit this letter on behalf of their futures commission merchant and provisionally registered…
Draft Technical Specifications for Certain Swap Data Elements
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the Draft Technical Specifications for Certain Swap Data Elements.…
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)…
Swap Dealer De Minimis Exception Preliminary Report
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provided comments to the Commodity Futures Trading Commission (CFTC) regarding…
Regulatory Capital Treatment of Settled to Market Cleared OTC Derivative Contracts
SIFMA provided comments to multiple agencies to inform them of a forthcoming change in market practice for cleared derivatives. Specifically,…
Business Conduct Standards
SIFMA provides comments to the Securities and Exchange Commission (SEC) on Business Conduct Standards for Security-Based Swap Dealers and Major…
Title VII Swap Execution Facility and Trade Execution Regulatory Framework and Implementation
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) in developing the swap execution facility (SEF) and related trade…
CPMI-IOSCO UTI Harmonization Consultation
SIFMA with the International Swaps and Derivatives Association (ISDA), the Institute of International Finance (IIF), The Investment Association provide comments to…
Security-Based Swap CCO/Supervision Standards
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the internal business conduct standards for security-based swap dealers…
Cross Border Margin Proposal
SIFMA and the Institute of International Bankers (IIB) provide comments to the Commodity Futures Trading Commission (CFTC) regarding the cross-border application…
Business Conduct Standards for Security-Based Swap Dealers
SIFMA Provides comments to the Securities and Exchange Commission (SEC) on the external business conduct standards for security-based swap dealers…
CFTC Cross-Border Margin Rule
SIFMA provides comments to Prudential Regulators asking them to defer finalization of their rules governing the cross-border application of margin…
Title VII Requirements to Security-Based Swap Transactions
SIFMA and the Financial Services Roundtable (FSR) provide comments to the Securities and Exchange Commission (SEC) on the Proposed Rules…
Inter-affiliate IM Requirements for Covered Swap Entities
SIFMA, The Clearing House Association L.L.C. (TCH), the American Bankers Association (ABA) and the ABA Securities Association (ABASA) provide comments…
District Court Remand Order in SIFMA et al. v. CFTC
SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provided Comments to the CFTC in response to District Court Remand…
Proposed Rules, Rule Amendments, and Guidance in Regulation SBSR
SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provided Comments to the SEC in response to the proposed rules,…
Sequencing of the Compliance Dates for SBS Final Rules
SIFMA provided additional comments to the Securities and Exchange Commission (SEC) on the SEC's Statement of General Policy on the…
Treatment of Certain Communications Involving Security-Based Swaps That May Be Purchased Only by Eligible Contract Participants
SIFMA provides comments to the Securities and Exchange Commission (SEC) in regards to rule proposal to provide that certain communications…
Margin and Capital Requirements for Covered Swap Entities
SIFMA provided comments to multiple agencies, including the Commodity Futures Trading Commission (CFTC) and U.S. prudential regulators, regarding their proposals…
SEC Recordkeeping and Reporting Proposal
SIFMA submitted comments to the Securities and Exchange Commission (SEC) regarding its proposal on recordkeeping, reporting, notification, and security count…
Draft RTS on Risk Mitigation Techniques for OTC-Derivative Contracts Not Cleared by a CCP
SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the European Securities and Markets Authority (ESMA), the…
Position Limits for Derivatives and Aggregation of Positions
SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission’s (CFTC) in response to…
Industry SEF Filing & Transactions to be Treated Independent for MAT Determinations
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on comments on Industry Filing IF 14-003 (ICE SEF Filing)…
Margin Requirements for Non-Centrally Cleared Swaps & Security-Based Swaps
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC), the Securities and Exchange Commission (SEC), the Board of Governors…
Time-Limited No-Action Relief Relating to SEF Confirmations
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting for time-limited no-action relief relating to confirmations for swaps…
Regulation of Swaps Between Non-US Swap Dealers & Non-US Counterparties
SIFMA, the Futures Industry Association (FIA), and The Financial Services Roudtable (FSR) provide the Commodity Futures Trading Commission (CFTC) on…
CFTC Position Limits for Derivatives
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Made Available to Trade Submission by Bloomberg of Certain CDS and Interest Rate Swaps
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity and Futures Trading Commission (CFTC)…
MarketAxcess’s Made Available to Trade Determination
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Tradeweb’s Made Available to Trade Determination
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
CFTC Regarding the Made Available to Trade Submission by Javelin for Certain Interest Rate Swaps
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) regarding…
The Made Available to Trade Submission by trueEX, LLC for Certain Interest Rate Swaps
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) regarding…
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…
Cross-Border Security-Based Swap Activities, Regulation SBSR, & Registration of SBSDs & MSBSPs
SIFMA, the Futures Industry Association (FIA), and The Financial Services Roundtable (FSR) provide comments to the Securities and Exchange Commission…
Compliance Issues Relating to Certain Swap Regulations
SIFMA, the Futures Industry Association (FIA) and The Financial Services Roundtable (FSR) provide comments to the Commodity Futures Trading Commission…
Exemptive Order Regarding Compliance with Certain Swap Regulations
SIFMA, the American Bankers Association (ABA), the ABA Securities Association, the Futures Industry Association (FIA), the Institute of International Bankers (IIB), and the International…
Requesting a Comment Deadline Extension for Certain Security-Based Swaps Rulemakings
SIFMA, The Financial Services Roundtable (FSR), the Futures Industry Association (FIA), the Institute of International Bankers, the International Swaps and Derivatives Association, Inc.…
Tax Position Overview as Prepared for the US House Ways and Means Committee
SIFMA provides comments to the U.S. House Ways and Means Committee on the Committee's Financial Products Discussion Draft (the Draft)…
Upcoming Meetings with European Finance Officials
SIFMA provides comments to U.S. Treasury Secretary Jacob Lew raising a number of important financial regulatory, tax and trade issues…
Margin Requirements for Non-Centrally-Cleared Derivatives
SIFMA provides comments to the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) on…
No-Action Relief for Recordkeeping Requirements
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting additional no-action relief from certain recordkeeping requirements under Subpart…
Capital, Margin & Segregation Requirements for SBS Dealers & MSBS Participants & Capital Requirements for BDs
SIFMA provides comments to the SEC on Capital, Margin and Segregation Requirements for Security-Based Swap Dealers (SBSDs) and Major Security-Based…
Compliance with Certain Swap Regulations
SIFMA, The Clearing House (TCH) and The Financial Services Roundatable (FSR) provide comments to the Commodity Futures Trading Commission (CFTC)…
Cross-Border Cash-Collateralized Derivatives Transactions
SIFMA provides comments with to the U.S. Department of Treasury and the Internal Revenue Service (IRS) on guidance under Section 956…
CME’s Swap Data Repository Rulebook
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the Chicago Merchantile Exchange, Inc.'s (CME's) submission (Proposed Rule) to make…
Capital, Margin, & Segregation Requirements for Swaps
SIFMA provides comments to the Securities and Exchange Commission (SEC) requesting a comment deadline extension on the capital, margin, and segregation…
Temporary Exemptions for Uncleared Security-Based Swaps
SIFMA provides additional comments to the Securities and Exchange Commission (SEC) on temporarily exempting uncleared security-based swaps (SBS) entered into…
Proposed Rule to Expand the Scope of Consumer Financial Privacy
SIFMA sent comments to the CFTC on Privacy of Consumer Financial Information; Conforming Amendments Under Dodd-Frank Act (“Notice”) which proposes…
SEC’s Exemptive Order & Security-Based Swaps Interim Final Rules
SIFMA provides comments to the Securities and Exchange Commission (SEC) requesting an extension of the expiration date of the SEC’s Exchange Act…
Margin & Capital Requirements for Covered Swap Entities
SIFMA provides comments to the Board of Governors of the Federal Reserve (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC),…
Consultative Document on Margin Requirements for Non-Centrally-Cleared Derivatives
SIFMA provides comments to the Working Group on Margining Requirements of the Basel Committee on Banking Supervision (BCBS) and the International Organization…
Clearing Exemption for Swaps Between Affiliated Entities
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on a notice of…
Margin Requirements for Uncleared Swaps for Swap Dealers & MSPs
SIFMA and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) regarding the proposed rulemaking…
Guidance Related to Cross-Border Application of Certain Swaps Provisions
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed interpretive guidance on the cross-border application of certain…
The Sequencing of the Compliance Dates for Security-Based Swaps Final Rules
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC's Statement of General Policy on the sequencing of…
Exemptive Relief for Compliance with Certain Swap Regulations
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the proposed exemptive order regarding compliance with certain swap…
Request for No-Action Relief: Recordkeeping Requirements under the Internal Business Conduct Rules
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) requesting no-action relief for recordkeeping requirements under the Internal Business…
Extension for Two Proposals Affecting Swaps
SIFMA and 9 other associations provide comments to the Commodity Futures Trading Commission (CFTC) requesting a comment deadline extension on the Cross-Border Proposed…
The Proposed Schedule for Dodd-Frank Title VII Rulemaking
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on a proposed…
Aggregation, Position Limits for Futures & Swaps
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Parameters for Large Notional Off-Facility Swaps & Block Trades
SIFMA and the International Swaps and Derivatives Association, Inc. provide comments to the Commodity Futures Trading Commission (CFTC) on proposed…
Treatment of Inter-Affiliate Transactions
SIFMA and the International Swaps and Derivatives Association, Inc. provide comments to the Commodity Futures Trading Commission (CFTC) on the treatment…
Uncleared Security-Based Swap Transactions Involving Eligible Contract Participants
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) to the Securities and Exchange Commission (SEC) on interim final…
Guidance on the Real-Time Reporting Rule
SIFMA and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) requesting interpretative…
Legislation Related to Certain Swap Activities
SIFMA provides comments to U.S. Representative Nan Hayworth, a sponsor of H.R. 1838, a bill to repeal a provision of…
Proposed Process to Make Swaps Available to Trade
SIFMA, the Futures Industry Association (FIA) and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity…
Registration of Swap Dealers & Major Swap Participants
SIFMA, the ABA Securities Association (ABASA), The Clearing House (TCH), The Financial Services Roundtable (FSR), the Futures Industry Association (FIA),…
Cleared Security-Based Swap Transactions Involving Eligible Contract Participants
SIFMA, FSR and ISDA provide comments to the Securities and Exchange Commission (SEC) on proposed exemptions for security-based swaps issued by registered or…
Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants
SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed registration requirements for security-based swap dealers (SBSDs) and…
SEC Re Treatment of Security-Based Swaps as Securities (December 2011)
SIFMA provides preliminary comments to the Securities and Exchange Commission (SEC) regarding a request for permanent exemption of security-based swaps…
Proposed Amendments Regarding Effective Date for Swap Regulation
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on proposed amendments regarding the effective date for swap regulation,…
Retirement Income Protection Act
SIFMA provides comments to the U.S. House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises supporting the Retirement…
Legislation to Exempt Certain Inter-Affiliate Transactions Under the Dodd-Frank Act
SIFMA provides comments to the U.S. House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises support H.R. 2779,…
Legislation Related to Section 716 of the Dodd-Frank Act
SIFMA provides comments to the U.S House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises supporting H.R. 1838,…
Compliance Schedules for Clearing, Trade Execution, Documentation & Margin
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures…
SEC Re Treatment of Security-Based Swaps as Securities
SIFMA provides preliminary comments to the Securities and Exchange Commission (SEC) regarding a request for permanent exemption of security-based swaps…
Retail Foreign Exchange Transactions
SIFMA, and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) on the…
OTC Derivatives Data Reporting & Aggregation Requirements
SIFMA, as part of a Coalition, provides comments to IOSCO on their August 2011 IOSCO-CPSS Consultation Report on OTC derivatives data…
Business Conduct Standards & CCO Requirements
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provide supplemental comments to the…
Canadian Securities Consultation Paper Regarding Trade Repositories
The Global Foreign Exchange Division (GFXD) provides comments to the Canadian Securities administrators on the Consultation Paper 91-402 Derivatives: Trade Repositories. …
Treatment of Inter-Affiliate Transactions Under the Dodd-Frank Act
SIFMA, the ABA Securities Association, the American Council of Life Insurers (ACLI), the Futures Industry Association (FIA), the Institute of…
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…
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…
Joint Proposals Defining ‘Swap,’ ‘Security-Based Swap,’ & ‘Security-Based Swap Agreement’
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on joint proposed…
Margin Requirements for Uncleared Swaps for Swap Dealers & Major Swap Participants
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Rule 9j-1 of the Dodd-Frank Act
SIFMA provides comments to the Securities and Exchange Commission (SEC) on Proposed Rule 9j-1; Release No. 34-63236; File No. S7-32-10. The…
Swap Dealer/MSP Capital Requirements Proposal
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading…
Margin & Capital Requirements for Covered Swap Entities
SIFMA and the International Swaps Dealers Association, Inc. (ISDA) provide comments to the Office of the Comptroller of the Currency (OCC),…
Effective Dates for Certain Swap Regulations
SIFMA, the American Bankers Association, the ABA Securities Association, the Futures Industry Association, the Institute of International Bankers, the International…
Clarification & Relief Under Section 774 of the Dodd-Frank Act
SIFMA, American Bankers Association (ABA), Financial Services Roundtable, Futures Industry Association (FIA), Institute of International Bankers, International Swaps and Derivatives…
Clarification & Relief Under Sections 754 and 739 of the Dodd-Frank Act
SIFMA, the Futures Industry Association (FIA), the Institute of International Bankers (IIB), the International Swaps and Derivatives Association, Inc. (ISDA),…
Foreign Exchange Swaps & Foreign Exchange Forwards
The Global FX Division of SIFMA, AFME and ASIFMA provide comments to the U.S. Department of Treasury on the U.S.…
Designation of a Chief Compliance Officer for FCMs, SDs & MSPs
SIFMA and the Futures Industry Association (FIA) provide supplemental comments to the Commodity Futures Trading Commission (CFTC) on the designation of…
Re-proposal of Rules Implementing Title VII of Dodd-Frank Act
SIFMA and other associations provide comments to the Securities and Exchange Commission (SEC) on the re-proposal of rules implementing Title VII…
Reopening & Extension of Comment Periods for Rulemakings Implementing Dodd-Frank Act
SIFMA and other trade associations provide comments to the Commodity Futures Trading Commission (CFTC) on a proposal for the reopening…
Antidisruptive Practices Authority Proposed Interpretive Order
SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on an antidisruptive practices authority…
Phase-In Schedule for Derivative Requirements of Dodd-Frank Act
SIFMA, the Financial Services Forum (FSF), the Futures Industry Association (FIA) and the International Swaps Dealers Association, Inc. (ISDA) provide…
Proposed Ownership Limitations
SIFMA, the American Bankers Association (ABA), the Financial Services Roundtable (FSR), the Futures Industry Association (FIA), and the International Swaps and…
Swap Trading Documentation Requirements for Swap Dealers
SIFMA and the International Swap Dealers Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on swap trading relationship documentation…
Registration & Regulation of Security-Based Swap Execution Facilities
SIFMA and the International Swaps Dealers Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) on the…
Notice of Proposed Rulemaking Relating to Position Limits for Derivatives
SIFMA and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on a Notice of…
Proposed Principles & Requirements for Swap Execution Facilities
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Tax Treatment of Derivative Positions Assumed by Affiliated Entities
SIFMA provides comments to the U.S. Department of Treasury and the Internal Revenue Service (IRS) requesting guidance on implementation of Title VII of…
De Minimis Exception from Certain Swap Participant Definitions
SIFMA's Regional Dealers Derivatives Committee provides comments to the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission…
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…
Business Conduct Standards
SIFMA, the American Bankers Association, the American Benefits Council, the Committee on Investment of Employee Benefit Assets, The ERISA Industry…
Proposed Rules for End-User Exception to Mandatory Clearing of Swaps
SIFMA's Municipal Finance Products Committee provides comments to the Commodity Future Trading Commission (CFTC) and the Securities and Exchange Commission (SEC)…
Business Conduct Standards for Swap Dealers and Major Swap Participants
SIFMA and the International Swap Dealers Association (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on business conduct…
Three Proposed Rules Relating to Recordkeeping & Reporting of Swaps Data
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
BCBS Bank Exposures to Central Counterparties
The Global Financial Markets Association (GFMA), the British Bankers Association (BBA), the Institute of International Finance (IIF), and the International…
CFTC Proposed Rules Relating to the Implementation of Whistleblower Provisions
SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on proposed rules for implementing whistleblower…
Extraterritorial Application of Title VII of the Dodd-Frank Act
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC), the Securities and Exchange Commission (SEC), the Board of Governors…
CFTC Proposal Relating to the Protection of Collateral of Counterparties to Uncleared Swaps
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on proposed rulemaking…
Duties of Swap Dealers & Major Swap Participants
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the CFTC's proposed rulemaking regarding duties of swap dealers and major…
Proposed Regulation SBSR Under the Securities & Exchange Act of 1934
SIFMA and International Swaps and Derivatives Association, Inc (ISDA) provide comments to the Securities and Exchange Commission (SEC) on a proposal relating…
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…
Conflict of Interest Policies & Procedures for FCMs, IBs & SDs & MSPs
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association, Inc. (ISDA) provides comments to the Commodity…
Designation of a Chief Compliance Officer; Required Compliance Policies; and Annual Report of a Futures Commission Merchant, Swap Dealer, or Major Swap Participant
SIFMA and the Futures Industry Association (FIA) provide comments to the Commodity Futures Trading Commission (CFTC) on proposed rules relating…
Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities Regarding the Mitigation of Conflicts of Interest
SIFMA, the ABA Securities Association, the Clearing House Association L.L.C., the Financial Services Roundtable (FSR), the Futures Industry Association (FIA), and International…
Proposed Regulations Regarding Position Limits for Derivatives
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments in response to a proposed rule currently under…
Antidisruptive Practices Authority
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Study Relating to the Standardized Computer-Readable Descriptions of Complex & Standardized Derivatives
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on…
Proposed Rulemaking on the Prohibition of Market Manipulation
SIFMA, the Futures Industry Association (FIA), and the International Swaps and Derivatives Association (ISDA) provide comments to the Commodity Futures Trading Commission…
Antimanipulation Provisions of the Exchange Act
SIFMA and the International Swaps and Derivatives Association (ISDA) provide comments to the Securities and Exchange Commission (SEC) on a proposed rule,…
Privacy of Consumer Financial Information; Conforming Amendments Under Dodd- Frank Act
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on Privacy of Consumer Financial Information; Conforming Amendments Under Dodd-Frank, Act…
Business Affiliate Marketing
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the Business Affiliate Marketing and Disposal of Consumer Information Rules, RIN…
Comment Periods and Implementation of New Derivatives Regulations
SIFMA, the American Bankers Association (ABA), the ABA Securities Association, The Clearing House Association L.L.C. (TCH), the Financial Services Forum…
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…
Proposed Limits on Ownership or Voting Power of Derivative Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities
SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) on proposed limits on…
Swap Dealer Registration Requirements, Swap End User Clearing Exemption
The Regional Dealers Derivatives Committee of SIFMA provides comments to the Commodity Futures Trading Commission (CFTC) and Securities and Exchange…
Business Conduct Standards
SIFMA and International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Securities and Exchange Commission (SEC) and Commodity Futures…
Rules of the Judicial Conference of the US on Bankruptcy Procedures
SIFMA and the Loan Syndications and Trading Association (LSTA) provide comments to the Committee on Rules of the Judicial Conference of the…
Securities Exchange Act
SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the Financial Industry Regulatory Authority's (FINRA's) proposed rule that consolidate…
Establishing Margin Requirements for Transactions in Credit Default Swaps
The Capital Steering Committee of SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on Regulatory Notice 09-30 establishing…
NCOIL Model Legislation
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Task Force on Credit Default Swaps Regulation…
Proposed Model Legislation to Regulate Credit Default Swaps
SIFMA provides comments to the National Conference of Insurance Legislators (NCOIL) on the proposed rulemaking clarifying the scope of the…
Front Running of Block Transactions
SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on Front Running of Block Transactions, Regulatory Notice 08-83. The proposal would codify the…
Speculation Legislation
SIFMA and seven other associations provide comments to the Speaker of the House of the U.S. House of Representatives and the House…
The Commodity Markets Transparency and Accountability Act
SIFMA provides comments to the U.S. House of Representatives Speaker of the House and the Minority Leader opposing The Commodity Markets Transparency…
Commodity Markets Transparency and Accountability Act of 2008
SIFMA and other associations provide comments to the U.S. House of Representatives on the Commodity Markets Transparency and Accountability Act of…
Oil Prices
SIFMA, along with the Commodity Markets Council (CMC), the Futures Industry Association (FIA), the International Swaps and Derivatives Association (ISDA), Managed…
Clearing and Settlement in the Derivatives Markets
SIFMA's European Securities Services Forum (ESSF) provides comments to the Office of Fair Trading (OFT) on competition concerns relating to clearing…
Improvement of the Credit & Equity Derivatives Markets
The Asset Management Group (AMG) of SIFMA and industry leaders provide comments to the Federal Reserve Bank of New York on improvements to…
Agriculture on Reauthorizing the Commodity Exchange Act
SIFMA, the Futures Industry Association (FIA), the International Swaps and Derivatives Association, Inc. (ISDA), and the Managed Funds Association (MFA) provide…
CESR on Non-Equity Markets Transparency
SIFMA, the European Primary Dealers Association (EPDA) and the European High Yield Association (EHYA) provides comments to the Committee of European…
SIA, TBMA & ISDA on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities
The Securities Industry Association (SIA)*, The Bond Market Association (TBMA)* and the International Swaps and Derivatives Association (ISDA) provide comments…
Disclosure Obligations of Certain Derivatives Counterparties
The Bond Market Association (TBMA)*, the International Swaps and Derivatives Association, Inc. (ISDA), and American Securitization Forum (ASF) provide comments to…
Proposed Change to Position Limits and Position Reporting Obligations
The Derivatives Products Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a National Association…
Proposals to Amend the Portfolio Pilot Program
The Ad Hoc Portfolio Margining Committee, the Derivatives Product Committee and the Options Committee of the Securities Industry Association (SIA)* provides comments to…
Proposed Supervisory Policy Statement on Investment Securities and End-User Derivatives Activities
The Bond Market Association (TBMA)* provides comments to the Federal Financial Institutions Examination Council (FFIEC) on proposed Supervisory Policy Statement on…
Accounting for Derivative and Similar Financial Instruments
The OTC Derivative Products Committee of the Securities Industry Association (SIA)* provide comments to the Financial Accounting Standards Board (FASB)…
Exposure Draft on Accounting for Derivative Financial Instruments
The Securities Industry Association (SIA)* provides comments to the Financial Accounting Standards Advisory Council (FASAC) on the Exposure Draft on Accounting…
Accounting Treatment of Financial Derivatives
The Over-The-Counter (OTC) Derivatives Committee of the Securities Industry Association (SIA)* provides comments to the U.S. Senate Banking Securities Subcommittee on the…
Proposals by the SEC and FASB Relating to Accounting Treatment of Financial Derivatives
The Securities Industry Association (SIA)* provides comments to the U.S. Senate Banking Subcommittee on Securities on the report, Proposals by the Securities and…