On Nov. 19, FIA submitted a letter to the Securities and Exchange Commission in response to a re-opening of the comment period on proposed rules relating to single-name credit default swaps and other security-based swaps. The proposed rules, which include capital, margin and segregation requirements for security-based swap dealers, was first issued in November 2012 but never finalized. In October 2018, the SEC updated the proposal and re-opened the comment period to seek additional feedback from market participants. In its letter, FIA urged the SEC to reconsider a proposed requirement that clearing firms seek SEC approval for their margin methodologies and internal risk models. Instead the SEC should adopt a "harmonized approach" that defers to the standard margin methodologies used by clearinghouses such as ICE Clear Credit, FIA said. In addition, FIA urged the SEC to coordinate with the Commodity Futures Trading Commission regarding the proposed capital requirements and pointed in particular to three proposed amendments that could impair the ability of clearing firms to clear security-based swaps.
