On March 3, FIA filed a response to a CFTC request for additional comment on its proposed capital requirements for swap dealers and major swap participants. FIA focused its response on the potential impact on futures commission merchants, and in particular a provision in the proposal that would require FCMs to include proprietary positions in swaps and security-based swaps in their calculations of the eight-percent risk-margin capital requirement. Current rules already have a provision that requires these firms to take a capital charge for these positions under a different calculation, FIA said, making it unnecessary to require them to take an additional charge based on eight percent of risk margin. In addition, this provision would place an "unacceptable financial burden on FCMs" and could make it more difficult and more expensive for smaller commercial end-users to hedge their risks, FIA said.
