In a joint letter, the trade associations requested that the prudential regulators exempt transactions between affiliates ("inter-affiliate swaps") from swaps initial margin ("IM") requirements. The trade associations noted that the CFTC, as well as regulators in the EU, Japan and other G20 jurisdictions, do not require initial margin between affiliates. The trade associations stated that the affiliate IM requirements:
impose a competitive, growing economic burden on U.S. firms;
incentivize firms to engage in risky and complex activity;
do not effectively address risks to U.S.-insured banks; and
depart from other requirements under the Dodd-Frank Title VII framework.
The signers of the letter are the American Bankers Association, the ABA Securities Association, the Bank Policy Institute, the U.S. Chamber of Commerce Center for Capital Markets Competitiveness, the Financial Services Forum, the Institute of International Bankers, ISDA and SIFMA.