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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
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

Good Afternoon: 

Please find the attached letter in response to the proposed rule and request for comment on Margin and Capital Requirements for Covered Swap Entities submitted by the Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”) and the American Council of Life Insurers (“ACLI”). 

If you have any questions please contact any of the letter’s signatories.  


Andrew Ruggiero

Senior Associate & Assistant General Counsel

SIFMA Asset Management Group

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

P: 212-313-1128 | C: 917-685-4663