Comment Text:
The attached comment letter is being submitted a second time today as I was unable to determine whether you received the first submission. Sack Consulting is an adviser to the Market Practices Committee of the Association of Institutional INVESTORS. The attached comment letter is being submitted on behalf of the Association in support of the October 4, 2011 Petition of ICE Clear Credit LLC to the Commission relating to portfolio margining of CDS transactions. Thank you for this opportunity to submit comments regarding this matter.
