Comment Text:
The Asset Management Group of the Securities Industry and Financial Markets Association ("SIFMA AMG" or "AMG") appreciates the opportunity to provide the Commission with comments and recommendations regarding the Commission’s Notice of Proposed Rulemaking to mandate the clearing of certain interest rate swaps. For the reasons stated in the comment letter, SIFMA AMG recommends that the Commission (1) defer the compliance date for any final clearing mandate until 180 days after a regulator in a non-U.S. jurisdiction has adopted an analogous mandate and do so with a phased-in approach by counterparty type; and (2) temporarily suspend acceptance of MAT submissions that could follow the Commission’s issuance of the clearing mandates set forth in the Proposed Determination until the Commission finalizes adjustments to the MAT process.
