SIFMA and its European affiliate, the Association for Financial Markets in Europe ("AFME"), submitted the attached comments to the European Commission and the National Security Council urging the U.S. and EU to negotiate a comprehensive Transatlantic Trade and Investment Partnership ("TTIP") that includes for financial services the following: conventional market access rules, and a mechanism to ensure an efficient, cost-effective and compatible regulatory framework. The groups propose a framework for enhancing financial regulatory cooperation that would facilitate and guide efforts to promote

The Asset Management Group ("AMG") of SIFMA submitted comments (linked below) to the CFTC requesting that the Commission take prompt action to provide relief from the terms of the minimum liquidation time of 5 days for the calculation of initial margin requirements on cleared swaps (other than those relating to physical commodities). In its letter, AMG states that the minimum liquidation time of 5 days for non-commodity swaps: is arbitrary and overly conservative; is based on a fundamentally flawed assumption as to a difference in liquidity between futures and swaps; creates an artificial

The Asset Management Group ("AMG") submitted a number of requests to the CFTC asking that the CFTC extend compliance dates, preferably by interim rule or CFTC Interpretative Guidance, but, failing that, by no-action letter, and that it suspend or disapply certain of its rules as to FX and cleared block transactions. Delay in Business Conduct and Information Collection Rules. First, AMG requested that the effectiveness of the business conduct rules be suspended until November 1, 2013. According to AMG, firms simply will not be ready to comply by May 1 and, if the rules come into effect on that

The Asset Management Group (AMG) of SIFMA submitted the attached comment letter to the CFTC requesting that the Commission grant an extension of the compliance date for the reporting obligations under CFTC Rules Parts 43 (real time public reporting) 45 (swap data record keeping and reporting) and 46 (swap data record keeping and reporting for pre-enactment and transition swaps) applicable to non-swap dealers and non-major swap participants until October 10, 2013. SIFMA AMG stated that it agrees with other industry groups that many non-swap dealers and non-major swap participants have yet to

This Exchange Notice provides guidance with respect to ICE Futures U.S. Rules 6.15 "Reportable Positions and Daily Reports" and 18.05 "Open Interest in Energy Contracts." See the IFUS Rulebook for the complete text of Rules 6.15 and 18.05. View Notice here (links externally to ICE website).