The Asset Management Group of SIFMA (SIFMA AMG) and the Managed Funds Association (MFA) provide comments to the Commodity Futures Trading Commission (CFTC) requesting interpretive guidance and relief on the application of CFTC Final Rule on Adaptation of Regulations to Incorporate Swaps – Records of Transactions [Rule 1.35(a)] to asset managers that would take one of the following forms:  

• exempt Asset Managers that participate on swap execution facilities (SEFs) from the oral and the written recordkeeping requirements;
• suspend and re-propose the Rule as it applies to Asset Managers that may be treated as members of SEFs, including a detailed cost-benefit analysis that addresses application of the Rule to Asset Managers that are members of SEFs, and, if the re-proposed Rule is adopted, provide an implementation period of at least one year from the new adoption date; or, 
• if the Commission is unwilling to adopt either of the forgoing alternatives, postpone the compliance date of the Rule with respect to Asset Managers that are members of SEFs until December 31, 2014.