Capital and Margin Requirements for Covered Swap Entities
To Appropriate FCA Staff: Please find attached two letters submitted by Managed Funds Association (“MFA”) in response to the reopening of the comment period for the proposed “Margin and Capital Requirements,” FCA RIN 3052-AC69. The first letter is MFA’s supplemental comment letter, and the second letter is MFA’s accompanying letter discussing the benefits and legal analysis supporting the continued use of cross-product portfolio margining arrangements by market participants.
Thank you for your consideration of both letters.
Best regards. Laura S. Harper I Assistant General Counsel Managed Funds Association
600 14th Street, NW, Suite 900 I Washington, DC 20005 firstname.lastname@example.org Iwww.managedfunds.org
T: 202.730.2600 I C: 202.695.4407 I F: 202.730.2601