In a comment letter yesterday, ABA and its ABA Securities Association subsidiary yesterday urged the Commodity Futures Trading Commission to consider the competitive implications that proposed margin requirements would have on banking organizations that operate globally.
ABA — commenting through its new Center for Bank Derivatives Policy — and ABASA also recommended that regulators provide a limited exception for U.S.-based banking organizations that are operating in emerging markets where there may be legal and operational constraints that would make compliance with margin requirements difficult, if not impossible.