SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provide comments to the Commodity Futures Trading Commission (CFTC) on the recently released notice of proposed rulemaking and request for comments (NPR) concerning margin requirements for non-cleared swaps and non-cleared security-based swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act), RIN 3038-AC97. In addition to a discussion on margin requirements, the groups’ comments include, among other observations and recommendations, discussions on the potential macroeconomic effects, the issue of extraterritoriality, and requirements for entity types.