Comment from SIFMA and SIFMA Asset Management Group

Summary: The Securities Industry and Financial Markets Association (SIFMA) and its Asset Management Group support a recommendation to clarify that overnight U.S. Treasury reverse repurchase transactions cleared through the FICC are not treated as securities subject to the 5% asset test. They argue that treating these transactions as securities issued by a single issuer would unduly restrict mortgage REITs' ability to manage interest rate risk and invest in these highly liquid and safe assets.