In a letter submitted to the CFTC today, FIA PTG welcomed the finalization of the capital requirements for Swap Dealers with the following suggested modifications for non-bank Swap Dealers:
- Remove proprietary cleared derivatives from the eight percent initial margin capital requirement;
- Lower the eight percent initial margin capital requirement to two percent;
- Reduce standardized market risk charges for uncleared FX derivatives from 20 percent to six percent;
- Eliminate the 150 percent capital charge for non-clearing member Swap Dealers; and
- Allow enough time for new models to be approved.
