Comment Text:
Ladies and Gentlemen,
We appreciate the opportunity to provide comments to the Commission on the proposed rule on Margin on Uncleared Swaps for Swap Dealers and Major Swap Participants. Recognizing the value of expert analysis in informing regulators of the potential costs and benefits of the current rulemaking, the authors of this study, Dr. Sharon Brown-Hruska and Trevor Wagener of National Economic Research Associates, Inc., conducted a detailed quantitative impact study to analyze the potential costs and benefits of the proposed rule. We hope that the Commission finds our insights helpful as it considers improvements to the proposed rule.
Sincerely,
Dr. Sharon Brown-Hruska
Trevor Wagener
