Dodd Frank Section 165 has implications and impacts on the industry.

Dodd Frank Section 165 Section (d) and (e) are applicable to Securities Lending arrangements for US providers and will have certain implications and impacts on the industry.

RMA has published a comment letter on issues concerning application of the proposed rulemaking’s single-counterparty credit limits to Agency Securities Lending Programs in the US and related transactions. The rules address certain requirements including but not limited to client indemnification, overstatement of credit risk, impacts to liquidity and how they believe that these rules could potentially shut down clients participation in lending programs or move them to Foreign providers. RMA has made proposals based on VAR methodologies aligned with international capital rules and consistent with similar regulatory frameworks and have requested implementation of the rules to be extended to 2015.