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Return to Comments
Capital and Margin Requirements for Covered Swap Entities 2011 Proposal
Type: Regulation
Federal Register Document Type: Proposed
No Description.

Text of Comment Letter
The attached comments on the FCA’s proposed rulemaking, “Margin and Capital Requirements for Covered Swap Entities” [RIN 3052-AC69] are respectfully submitted by the following organizations:

American Resort Development Association

American Seniors Housing Association

Building Owners and Managers Association International    

CCIM Institute

Commercial Real Estate (CRE) Finance Council

International Council of Shopping Centers

Instituteof Real EstateManagement

NAIOP, the Commercial Real Estate Development Association

National Apartment Association

National Association of Real Estate Investment Trusts

National Association of Realtors®

National Multi Housing Council                                

Realtors® Land Institute

Society of Industrial and Office Realtors®

The Real Estate Roundtable

Kirk W. Freeman
Senior Director, Government Relations
National Association of Real Estate Investment Trusts® 
REITs: Building Dividends & Diversification®  
1875 I Street, NW, Suite 600, Washington, DC  20006
202-739-9415 (direct dial)
202-739-9400 (main line)
202-468-0305 (cell)


NAREIT® does not intend this email to be a solicitation related to any particular company, nor does it intend to provide investment, legal or tax advice. Investors should consult with their own investment, legal or tax advisers regarding the appropriateness of investing in any of the securities or investment strategies discussed in this publication. Nothing herein should be construed to be an endorsement by NAREIT of any specific company or products or as an offer to sell or a solicitation to buy any security or other financial instrument or to participate in any trading strategy. NAREIT expressly disclaims any liability for the accuracy, timeliness or completeness of data in this publication. Unless otherwise indicated, all data are derived from, and apply only to, publicly traded securities. All values are unaudited and subject to revision. Any investment returns or performance data (past, hypothetical, or otherwise) are not necessarily indicative of future returns or performance.

(See attached file: Real Estate Organizations - Proposed Margin Rules 7-11.pdf)