September 29, 2017

Mr. Christopher Kirkpatrick
Secretary
U.S. Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st St, N.W.
Washington, DC 20581

Re: Request for Information regarding Project KISS (RIN 3038-AE55)

Dear Mr. Kirkpatrick:

The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG” or “AMG”) 1 appreciates the opportunity to provide the following response to the Commodity Futures Trading Commission’s (the “Commission”) regulatory reform initiative branded “Project KISS.”2 AMG appreciates the Commission’s continuing engagement on this important review and hopes that it leads to achieving greater efficiencies in applying the Commodity Exchange Act (“CEA”) and Commission Regulations to the important financial markets within the Commission’s jurisdiction.

AMG, as the voice for fiduciaries who serve clients such as pension funds and retail funds, has seen some areas of post-crisis overcorrection and overregulation for which recalibration would help reduce costs ultimately borne by investors. While we believe core regulatory changes achieved by the Commission have strengthened markets and protected investors, overly prescriptive and limiting requirements on the periphery have had outsized consequences of creating unnecessary burdens and increasing operational complexity. In addition, AMG believes that some standards need to be modernized and updated to improve operational efficiencies for market participants. To provide specific comments on each of the areas identified by the Commission, AMG has submitted four appendices, each of which will be submitted via the KISS Public comment portal.

For the reasons detailed in the appendices, AMG makes the following recommendations:

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1 SIFMA AMG brings the asset management community together to provide views on policy matters and to create industry best practices. SIFMA AMG’s members represent U.S. and multinational asset management firms whose combined global assets under management exceed $39 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

2 See Project Kiss (Request for Information), 82 Fed. Reg. 23765 (May 24, 2017).