Futures Commission Merchant Regulation - Comment Letter - Securities Industry and Financial Markets Association - January 18, 2011

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Protection of Cleared Swaps Customers Before and After Commodity Broker Bankruptcies
January 18, 2011

From the comment letter:

“SIFMA is concerned about the possibility that fragmented segregation requirements will be adopted that place client collateral for OTC transactions, which are currently in one pool, into four separate pools – one for cleared swaps, one for uncleared swaps, one for cleared security-based swaps, one for uncleared security-based swaps – and thereby create barriers to portfolio margining across positions in these separate pools which can easily be portfolio margined today, replicating the current problem that creates for portfolio margining securities and futures positions. SIFMA urges the CFTC to comply with Dodd-Frank’s portfolio margining mandate and to work with the SEC towards consistent segregation regimes which would enable portfolio margining, not only across OTC derivatives positions, but also across swaps, futures, security-based swaps and securities positions.”


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