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The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to the Financial Conduct Authority ("FCA") requesting that it exclude To-Be-Announced trades ("TBAs") from the definition of derivative contracts under European Market Infrastructure Regulation ("EMIR"). In the letter, SIFMA AMG suggested that TBA trades should not be classed as derivative contracts for the following reasons: TBA trades are appropriately classified as spot trades (cash market trades) as they settle within the standard settlement cycle of the securities being purchased; TBA trades should be classified