From: Lauren Eardensohn Sarper
Sent: March 1, 2016
Subject: File No. SR-FINRA-2015-036

Dear Associate Director Macchiaroli,

On behalf of Prudential Financial and PMCC, I would like to thank you and your colleagues for meeting with us yesterday to discuss our comments on the January 21, 2016 Federal Register Notice titled “Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Instituting Proceedings To Determine Whether To Approve or Disapprove Proposed Rule Change To Amend FINRA Rule 4210 (Margin Requirements) To Establish Margin Requirements for the TBA Market, as Modified by Partial Amendment No. 1.” We greatly appreciate your willingness to listen to our concerns with the rules language and the potential impact margining could have on the multifamily housing market.

In follow up to our conversation, I would like to share with you our suggested language changes for  Rule 4210(e)(2)(H)(ii)(a)(2). We feel the following recommended language changes would alleviate a number of the issues concerning the rule:

"2. a member may elect not to apply the margining requirements specified in paragraph (e)(2)(H) of this Rule with respect shall not apply to Covered Agency Transactions with a counterpart in multifamily housing securities or project loan program securities, provided as long as"...