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Capital and Margin Requirements for Covered Swap Entities

The attached comments on the FCA’s proposed rulemaking, “Margin and Capital Requirements for Covered Swap Entities” [RIN 3052-AC69] are respectfully submitted by the following organizations:

American Resort Development Association

American Seniors Housing Association

Building Owners and Managers Association International    

CCIM Institute

Commercial Real Estate (CRE) Finance Council

International Council of Shopping Centers

Instituteof Real EstateManagement

NAIOP, the Commercial Real Estate Development Association

National Apartment Association

National Association of Real Estate Investment Trusts

National Association of Realtors®

National Multi Housing Council                                

Realtors® Land Institute

Society of Industrial and Office Realtors®

The Real Estate Roundtable

Kirk W. Freeman
Senior Director, Government Relations
National Association of Real Estate Investment Trusts® 
REITs: Building Dividends & Diversification®  
1875 I Street, NW, Suite 600, Washington, DC  20006
202-739-9415 (direct dial)
202-739-9400 (main line)
202-468-0305 (cell)


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Real Estate Organizations - Proposed Margin Rules 7-11.pdf - Real Estate Organizations - Proposed Margin Rules 7-11.pdf