SIFMA submitted a letter, dated November 26, 2012, to the various U.S. banking regulators to which SIFMA appended a prior letter, dated September 28, 2012, to the Basel banking regulators, in each case concerning margin requirements. The very short letter to the U.S. banking regulators thanks the banking regulators for reopening the comment period on the banking regulators’ margin rule for swaps and also asked that, if the banking regulators materially amend their proposed margin rules for swaps, that the revised rule be reissued as a proposal for public comment, rather than being simply adopted.
The much longer September letter to the Basel regulators provides a full commentary on proposed margin requirements issued in a Basel/IOSCO consultation paper. Notably, the September letter supports a limited requirement of two-way transfer of variation margin between financial counterparties. However, it opposes a number of other suggestions in the consultation paper including the mandated posting of initial margin on uncleared swaps by regulated financial institutions.
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