On July 19, 2018, the International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) published a white paper entitled "Initial Margin for Non-Centrally Cleared...more
The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more
On May 24, 2016, the Commodity Futures Trading Commission (“CFTC”) in a much anticipated action approved the issuance of final rules (“Final Rules”) regarding the cross-border application of its uncleared swaps margin...more
BACKGROUND - The five US prudential regulators for swaps (the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, the Comptroller of the Currency, the Farm Credit Administration and the...more
Under the Margin Rules, swap dealers and major swap participants that do not have a prudential regulator (Covered Swap Entities, or CSEs) would be required to collect and post initial margin for uncleared swaps with financial...more
To clarify our intended audience, in the Financial Entity Update we will address issues germane to entities that trade swaps but are neither dealers nor commercial end users. This includes a broad and diverse group of...more