On September 26, 2023, the “Export Enforcement Five” or “E5” partnership among the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance focused on preventing Russian...more
Earlier this week, following Russia’s aggressive incursion into Ukraine, we reported on the imposition of U.S. sanctions in response — a modest response that reserved the heavier sanctions that have been anticipated. On...more
On July 29, 2021, the Alternative Reference Rates Committee (“ARRC”) of the Federal Reserve formally announced and recommended1 CME Group’s forwardlooking Term Secured Overnight Financing Rate (“Term SOFR”) rates.2 Important...more
This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more
The Pandemic Crisis has offered the financial services sector a live stress test environment to assess its planning, systems, and processes for Operational Resilience. To explore this and see how institutions have fared so...more
On April 19, 2018, the Canadian Securities Administrators (CSA) took a major step toward adopting a comprehensive regime for the regulation of those in the business of trading derivatives or advising on derivatives. The CSA...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
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
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
Trade reporting obligations take effect in Ontario, Quebec and Manitoba (Applicable Provinces) on June 30, 2015 and will require over-the-counter (OTC) derivatives transactions between “End-Users” to be reported if either or...more