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Return to Comments
Margin and Capital Requirements for Covered Swap Entities Proposed Rule (LIBOR Amendments)
Type: Regulation
Federal Register Document Type: Proposed
Description:
Would amend the regulation governing Margin and Capital Requirements for Covered Swap Entities to clairify that certain non-cleared swaps would retain their legacy status if they are amended solely to substitute another reference rate for LIBOR as it is phased out and to address other issues.


Text of Comment Letter

Attached please find a letter in response to proposed amendments and request for comment on Margin and Capital Requirements for Covered Swap Entities submitted by the American Bankers Association, the ABA Securities Association, the Bank Policy Institute, the Center for Capital Markets Competitiveness of the U.S. Chamber of Commerce, the Financial Services Forum, the Institute of International Bankers, and the Securities Industry and Financial Markets Association to the following comment files:

DEPARTMENT OF THE TREASURY, Office of the Comptroller of the Currency

12 CFR Part 45

[Docket No. OCC–2019–0023]

RIN 1557–AE69

FEDERAL RESERVE SYSTEM

12 CFR Part 237

[Docket No. R–1682]

RIN 7100–AF62

FEDERAL DEPOSIT INSURANCE CORPORATION

12 CFR Part 349

RIN 3064–AF08

FARM CREDIT ADMINISTRATION

12 CFR Part 624

RIN 3052–AD38

FEDERAL HOUSING FINANCE AGENCY

12 CFR Part 1221

RIN 2590–AB03

Sincerely,

Kyle Brandon

Managing Director, Head of Derivatives Policy

SIFMA
120 Broadway, 35th  Floor, New York, NY 10271

Office: 212-313-1280

Mobile: 917-517-9924

kbrandon@sifma.org

www.sifma.org 

Attachments: