On July 23, 2020, the Commodity Futures Trading Commission (CFTC or Commission) voted 3-2 to approve a final rule (Final Rule) on the cross-border application of certain swap provisions under the Commodity Exchange Act (CEA)....more
If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more
Although the letter technically does not delay the effective date of March 1, 2017, from the perspective of the buy side, the letter functions as a “grace period,” and the compliance date has been moved to September 1, 2017....more
Because of the implementation of new regulatory requirements relating to both variation and initial margin for swaps, swap documentation for many market participants is about to become much more complicated....more
March 1, 2017, is the scheduled implementation date applicable for all insurance companies for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules. Although the...more
As has been rumored in recent weeks, the CFTC has adopted an order establishing December 31, 2018 as the swap dealer registration de minimis threshold phase-in termination date. With this approval, the de minimis threshold...more
Under current CFTC rules, market participants who exceed $8 billion in gross notional swap dealing activity over a twelve-month period are required to register with the CFTC as swap dealers during the phase-in period...more
On November 18, staff from the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight and Office of the Chief Economist issued a preliminary report regarding the swap dealer de minimis...more
Last fall both the Commodity Futures Trading Commission (“CFTC”) and five U.S. prudential banking regulators (the “Prudential Regulators”) released proposed rules for margin requirements for uncleared swap transactions for...more
On September 3, 2014, the Board of Governors of the Federal Reserve System (the Board) jointly adopted, with certain federal banking regulators, re-proposed rules that will require registered swap dealers, security-based swap...more
Federal banking regulators (the Prudential Regulators) have re-proposed regulations to require certain dealers and major participants in the swap and security-based swap markets to collect initial and variation margin for...more
On June 4, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter extending the relief provided by CFTC Letter No. 14-01...more
European Banking Authority Publishes Opinion on European Commission's Proposed Amendments to ITS - On April 16, the European Banking Authority (EBA) published via its website an opinion dated April 4, 2014 on...more
The Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) has delayed until January 14, 2014 the effectiveness its Advisory 13-69 issued on November 14 in which it took the position...more