SIFMA AMG and ISDA Request Extension of Comment Period for Proposed Rule on Aggregation of Positions

The Asset Management Group of SIFMA ("SIFMA AMG") and ISDA submitted comments to the CFTC requesting that the CFTC extend the comment period for the Aggregation Notice of Proposed Rulemaking in order to align it with the end of the comment period for the proposed rule regarding Position Limits for Derivatives.According to the comment letter, the two proposed rules were considered and adopted at the same CFTC public meeting on November 5, 2013. Therefore, the proposed rules are "deeply intertwined," and the agencies believe it is "essential to have sufficient time to review and comment on them together."

Moreover, the letter states that in order for members to fully ascertain the impact on their businesses, including compliance costs, the proposed rules must be comprehended in conjunction with one another, and considering their combined impact will require more time beyond January 14, 2014, which is the current comment deadline for the Aggregation of Positions proposed rule.

See: SIFMA AMG and ISDA Comment Letter.
See generally: CFTC Rule Calendar (accessible to Cabinet subscribers only).
Related news: CFTC Issues Proposed Position Limits Rule (Fed. Reg.)(December 12, 2013); CFTC Issues Proposed Position Limits Rule for Derivatives (Pre-Fed. Reg.) (with Zwirb Comment)(December 3, 2013); CFTC Publishes Proposed Rules for Aggregation of Positions (Fed. Reg. Version) (November 15, 2013) Key Differences between the Recent CFTC Position Limits Proposal and the Previously Vacated Final Position Limits Rule (with Delta Strategy Group Summary) (November 18, 2013); Cadwalader Memo on Proposed Position Limits and Aggregation Rules (with Lofchie Comment) (November 6, 2013); CFTC Approves Position Limits Proposal (with Lofchie and Zwirb Comments and Delta Strategy Group Summary) (November 5, 2013).