Comment Text:
Please accept these comments from the American Council of Life Insurers on the proposed amendments to the Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants that were published under RIN 3038–AE89 in 84 Federal Register 206 (October 24, 2019) at 56950. We offer the attached comments to request relief from the application of the final margin rules for uncleared swaps transactions with respect to initial margin upon investment funds initially funded with seed capital by a fund sponsor or affiliate and consolidated on the sponsor’s (or the sponsor’s group’s) financial statements (“seeded funds”) during the three year seeding period following a seeded investment fund’s launch. We have previously shared our views informally with CFTC staff in April 2019. The CFTC's proposed amendments provide an efficient and effective vehicle to provide the requested relief.
We have also filed a similar request for relief with the U.S. prudential regulators in an initiative proposing parallel amendments the Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants administered by the prudential regulators. Coordination between the CFTC and the prudential regulators on this request for relief would promote consistent regulatory standards and reasonable relief.
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