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October 20, 2015

FINRA's revised proposal to amend FINRA Rule 4210 ("Margin Requirements") was published in the Federal Register. The amendments would establish margin requirements for (i) to-be-announced transactions ("TBAs"), (ii) Specified Pool Transactions and (iii) transactions in Collateralized Mortgage Obligations. Comments on the proposal must be submitted by November 10, 2015.

November 11, 2015

SIFMA expressed concern about the clarity, operational feasibility and potential negative impact of FINRA’s proposal to establish margin requirements for transactions in the “to-be-announced” ("TBA") market. SIFMA filed a comment letter in response to FINRA's proposal to amend FINRA Rule 4210 ("Margin Requirements"). In the letter, SIFMA expressed significant concerns about the "impact of the proposal on the mortgage market (particularly as to whether the burdens of certain aspects of the proposal will cause either member firms or their counterparties to withdraw from parts of the market)."