SIFMA and its Asset Management Group ("SIFMA AMG") urged an 18-month period to implement margin requirements for "covered agency transactions" ("CATs") under FINRA Rule 4210  ("Margin Requirements"). The comment letter comes in response to an updated FINRA proposal to amend the rule for CATs, which included an effective date nine to 10 months following SEC approval.

The SIFMA letter states that the additional time is not enough to appropriately amend documentation and reprogram internal margin systems, and that an insufficient implementation time could lock some trading counterparties out of these markets entirely. SIFMA also noted that an extended period would reduce the overlap with other regulatory compliance initiatives, including the new SEC rules for security-based swaps and the ongoing phased implementation of initial margin requirements for uncleared derivatives.

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