CFTC Proposed Clearing Exemption for Swaps Between Affiliates

Orrick - Finance 20/20
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On August 16, the CFTC proposed an exemption from clearing requirements under Section 723 of the Dodd-Frank Act for swaps between certain affiliated entities within a corporate group. The proposed exemption would be limited to swaps between majority-owned affiliates and would require centralized risk management, swap trading relationship documentation, variation margin payments, and satisfaction of certain reporting requirements. Comments on the proposed rule must be submitted within 30 days of publication in the Federal Register. CFTC Release. CFTC Proposed Rule.

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