Buy-Side Associations Request Relief on Regulations to Incorporate Swaps Records of Transactions
The Asset Management Group of SIFMA ("SIFMA AMG") and the Managed Funds Association ("MFA") have submitted comments to the CFTC requesting interpretive guidance and relief on the application of CFTC Rule 1.35(a) ("Records of Commodity, Interest and Related Cash or Forward Transactions") to asset managers.
SIFMA AMG and the MFA request that the CFTC guidance and relief take one of the following forms (expressed in order of preference):
- exempt Asset Managers that participate on swap execution facilities ("SEFs") from the oral and written recordkeeping requirements;
- suspend and repropose the Rule as it applies to asset managers that may be treated as members of SEFs, include a detailed cost-benefit analysis that addresses application of the Rule to asset managers that are members of SEFs and, if the reproposed Rule is adopted, provide an implementation period of at least one year from the new adoption date; or
- if the CFTC is unwilling to adopt either of the forgoing alternatives, postpone the compliance date of the Rule with respect to asset managers that are members of SEFs until December 31, 2014.
See: SIFMA AMG and MFA Comment Letter.Related news: NFA Notice: New Recordkeeping Requirements (with comments from Lofchie and from Hollingsworth Consulting) (September 16, 2013).