The US Commodity Futures Trading Commission has approved an interim final rule extending the Phase 5 initial margin compliance deadline for uncleared swaps by one year....more
The current COVID-19 pandemic has led to huge disruption in financial markets and larger collateral swings. This note sets out some issues market participants may need to consider in relation to collateral under OTC...more
To help address market participants in the face of the coronavirus (COVID-19) crisis, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions have provided a one-year extension...more
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 International Securities and Derivatives Association has published a guide on the cross-border application of margin rules established under the U.S., EU and Japanese regimes for uncleared derivatives. While most...more
The Financial Stability Board has published a report on the progress its member jurisdictions have made in 2019 on the implementation of agreed G20 reforms to over-the-counter derivatives markets. The report finds that there...more
The target date at international level for regulators to introduce margin requirements for uncleared derivatives for counterparties with lower trading volumes has been extended for a year by the International Organization of...more
The Basel Committee on Banking Supervision and the International Organization of Securities Commissions have published a joint statement on the final implementation of the margin requirements for derivatives not cleared...more
BROKER-DEALER - SEC Chairman Clayton and Trading and Markets Director Redfearn Call for a Reassessment of Regulation NMS - On March 8, US Securities and Exchange Commission chairman Jay Clayton and director, Division...more
On February 23, 2017, the Joint Committee of European Supervisory Authorities (“ESAs“) published a statement on variation margin exchange under the EMIR regulatory technical standards (“RTS“) on risk mitigation techniques for...more
The European Supervisory Authorities, the Financial Conduct Authority, the US prudential regulators, including the Federal Reserve Board and the Office of the Comptroller of the Currency, and the International Organization of...more
On February 23, 2017, U.S. federal banking regulators (Prudential Regulators), European regulators and the International Organization of Securities Commissions (IOSCO) issued statements clarifying their expectations on...more
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
A parallel set of margin requirements is being proposed by the Canadian Securities Administrators’ (CSA) Derivatives Committee (Consultation Paper 95-401 – Margin and Collateral Requirements for Non-Centrally Cleared...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
The Office of the Superintendent of Financial Institutions (OSFI), Canada’s federal regulator of financial institutions, recently issued Guideline E-22 – Margin Requirements for Non-Centrally Cleared Derivatives? (Guideline)....more
On 8 March 2016, the three European Supervisory Authorities (ESAs) published their final draft regulatory technical standards in relation to the collateralisation of non-centrally cleared derivatives. The standards are to...more
On October 22, 2015, the Federal Deposit Insurance Corporation held an open meeting at which it voted to adopt: (i) final rules governing margin and capital requirements for uncleared swaps and (ii) an interim final rule to...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
On March 18, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions (IOSCO) published a “final” policy framework that establishes minimum global standards for margin...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
CFTC Proposes Margin Rules for Uncleared Swaps and Approves Special Treatment for Operations-Related Swaps With Certain Government-Owned Natural Gas and Electric Utilities - A few weeks after the Federal Reserve Bank...more
On September 2, the Basel Committee on Banking Supervision of the Bank for International Settlements (BIS) and the Board of the International Organization of Securities Commissions (IOSCO) jointly published a document...more
The Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) jointly issued a final policy framework (the “Policy Framework”) establishing minimum standards for...more