MFA, the American Council of Life Insurers (ACLI), and the Alternative Investment Management Association (AIMA) (collectively, the “Associations”) submitted a joint letter to SEC Chairman White and CFTC Chairman Gensler with a request for action by the two commissions to improve coordination and to facilitate portfolio margining for customers in the cleared credit default swaps (CDS) market. This letter follows up on recent meetings with representatives at the CFTC and the SEC. In the letter, the Associations further expressed members’ concerns with the SEC Staff’s imposition of needlessly high initial margin requirements on customers who want to participate in ICE Clear Credit’s (ICC) cleared CDS portfolio margining program for CDS indices and single-name CDS. SEC Staff is imposing a temporary level for customers at 1.5 or 2 times the level imposed on dealers using the same CDS portfolio margining program. The Associations believe this disparity has undermined policy goals to encourage clearing to reduce systemic risk, to protect investors, to reduce counterparty exposure and interconnectedness of both customers and dealers, and to establish an integrated and coordinated regulatory framework by the two commissions. The Associations requested the SEC to issue final approval of the margin methodologies of the seven broker-dealer/futures commission merchants that have applied for evaluation by SEC Staff and FINRA in a coordinated manner, at a level that matches the approved level for dealers, and as soon as possible in advance of the CFTC’s June 10 mandatory clearing deadline for Category 2 entities. In the interim, the Associations requested the SEC to modify the temporary customer margin levels to the ICC baseline margin level to match the level approved for dealers.