The Asset Management Group of SIFMA (SIFMA AMG) provides additional comments to the Commodity Futures Trading Commission (CFTC) on CFTC Rule §1.35(a) (the Rule) in connection with the CFTC Staff Public Roundtable to Discuss Dodd-Frank End-User Issues held on April 3, 2014.

SIFMA AMG renews its request to exempt Asset Managers that are members of swap execution facilities (SEFs) or members of designated contract markets (DCMs) from the oral and written recordkeeping requirements of the Rule.

At the very least, pending evaluation of the foregoing request, SIFMA AMG requests that the CFTC staff issue relief to postpone the compliance date for Asset Managers that are Members until December 31, 2014.

See also: SIFMA AMG and Managed Funds Association (MFA) Comments to the CFTC Requesting Guidance and Relief on Rule 1.35(a) (December 10, 2013)