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FINRA delays implementation of amendments to FINRA Rule 4210 to October 26, 2021

The Financial Industry Regulatory Authority, Inc. (FINRA) filed a proposed rule change with the Securities and Exchange Commission (SEC) on December 22, 2020, to once more delay the implementation of amendments to FINRA Rule...more

Coronavirus - Deferral of Phases 5 and 6 of initial margin requirements for uncleared OTC derivatives recommended by BCBS and...

On April 3, 2020, the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) issued a statement recommending an extension to Phases 5 and 6 of the initial margin...more

The Deadline for Compliance With the U.S. Variation Margin Rules Is Approaching! Are You Ready?

The requirement that non-cleared swaps be fully margined, which is one of the last pillars of Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), will take effect for “financial end-users”...more

ISDA Publishes Variation Margin Protocol

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol is intended as a tool to help market participants that will...more

European Regulators Publish Second Consultation Paper on Margin for OTC Derivatives

On June 10, the European Supervisory Authorities (ESA) published a second consultation paper on draft Regulatory Technical Standards (RTS) to implement the European Market Infrastructure Regulation (EMIR) requirement that...more

Congress Exempts Non-Financial End-Users, Their Agents and Certain Cooperatives From Non-Cleared Swap Margin Requirements in...

On January 8, 2015, the U.S. Senate approved legislation, by a 93-4 vote, to reauthorize the Terrorism Risk Insurance Act (“TRIA”). The legislation, dubbed the Terrorism Risk Insurance Program Reauthorization Act of 2015 (the...more

Regulators Publish Re-proposed Margin Requirements for Uncleared Swaps

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

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