News & Analysis as of

End-Users Margin Requirements

Hogan Lovells

Documentation changes may be required for commercial end users, funds, and other financial end users

Hogan Lovells on

The new year is here and with it two important developments in the derivatives markets for nonswap dealer clients to consider. The first development is the market response to the looming discontinuation of U.S. dollar LIBOR...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Phases of Initial Margin Requirements for Uncleared Swaps Expected to Spark Additional Margin Compliance Efforts

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

Troutman Pepper

Documentation for the New Swap Margin Rules and Thoughts for the Buy Side and End Users

Troutman Pepper on

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

Skadden, Arps, Slate, Meagher & Flom LLP

"Non-Cleared Swap Variation Margin Requirements to Spark Credit Support Annex Amendments for Financial End Users"

On March 1, 2017, new rules adopted by U.S. Prudential Regulators and the Commodity Futures Trading Commission (CFTC) will require registered swap dealers to post and collect daily variation margin for over-the-counter,...more

Holland & Knight LLP

Guide to U.S. Variation Margin Documentation for Financial End Users

Holland & Knight LLP on

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

McGuireWoods LLP

ISDA Launches 2016 Variation Margin Protocol to Facilitate Compliance With Margin Rules

McGuireWoods LLP on

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol will help market participants implement the new variation...more

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - April 2016

Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Goofy Haircut

McGuireWoods LLP on

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

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Know Thyself

McGuireWoods LLP on

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

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