The National Futures Association
("NFA"),
ISDA and SIFMA, among others, expressed support for the CFTC
proposal to amend See
previous coverage of the proposal
here.)
The NFA called the existing requirements "unnecessarily
prescriptive," and generally supported the various amendments
proposed by the CFTC. The NFA also requested that the CFTC clarify
whether
Rule 23.704(a) requires a quarterly report when a swap
dealer's collateral management arrangements are not in
compliance with a counterparty contract (as opposed to only when
they are in compliance).
SIFMA and ISDA expressed broad support for the CFTC-proposed
amendments. In addition, the groups (i) asked the CFTC to clarify
whether the notice regarding IM segregation rights must be provided
only at the beginning of the first swap between the parties or
whether it could be provided earlier - e.g., at the outset
of the relationship - and (ii) suggested that the quarterly notice
requirement in Rule 23.704(a)
