Melissa Jurgens, Secretary
Commodity Futures Trading Commission
1155 21st Street, N.W.
Washington, DC 20581

Elizabeth M. Murphy, Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, DC 20551

Office of the Comptroller of the
Currency
250 E Street, S.W.
Mail Stop 2-3
Washington, DC 20219

Robert E. Feldman, Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429

Alfred M. Pollard, General Counsel
Attention: Comments/RIN 2590-AA45
Federal Housing Finance Agency
Fourth Floor, 1700 G Street, N.W.
Washington, DC 20552

Gary K. Van Meter, Director
Office of Regulatory Policy
Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102

Re: Margin Requirements for Non-Centrally Cleared Swaps and SecurityBased Swaps

Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”) is writing with respect to the proposed margin requirements for non-centrally cleared swaps and security- based swaps (the “U.S. Margin Proposals”) published by the Prudential Regulators, the Commodity Futures Trading Commission (the “CFTC”) and the Securities and Exchange Commission (the “SEC,” and, together with the CFTC and the Prudential Regulators, the “Agencies”) pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”).2
We understand that the Agencies are considering modifications to the U.S. Margin Proposals in order to harmonize U.S. margin requirements for non-centrally cleared swaps and security-based swaps with the final policy framework agreed by the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) for margin requirements for non-centrally cleared derivatives (the “BCBS-IOSCO Framework”).3

In this letter, we summarize and discuss, for the consideration of the Agencies in their respective U.S. Margin re-Proposals, certain key issues that are either raised by national  implementation of the BCBS-IOSCO Framework or unresolved by the BCBS-IOSCO Framework. SIFMA believes that effective and consistent resolution of these issues across U.S.
and international regulators is necessary to achieve the objectives of the BCBS-IOSCO Framework.4  This letter is intended to complement the letter submitted to the Agencies by the
International Swaps and Derivatives Association (“ISDA”) on February 5, 2014.

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