U.S. federal regulators propose amendments to swap margin regulations to clarify treatment of certain amendments to legacy swaps

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The Dodd-Frank Act requires entities that engage in swap activities to either submit their swaps for clearing with a central clearinghouse or to collect and post collateral (margin) based on the daily mark-to-market exposure under the swaps, subject to certain exemptions, notably for non-financial entities that enter into swaps for the purposes of hedging or mitigating commercial risk. Financial institutions, funds, and other entities that are not eligible for an exemption are now, or will in the coming years become, subject to mandatory margin rules for uncleared swaps.

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