News & Analysis as of

Margin Requirements

Orrick - Structured Finance Group

CFTC Approves a Final Rule to Amend Uncleared Swap Margin Requirements

On November 19, the Commodity Futures Trading Commission (“CFTC”) announced that it approved a final rule to amend its uncleared swap margin requirements to better align with certain rules adopted by the Board of Governors of...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Articles on Smart Contracts, Updates to Uncleared Swap Margin Requirements and...

by Katten Muchin Rosenman LLP on

CFTC - CFTC’s LabCFTC Releases Primer on Smart Contracts - On November 27, the Commodity Futures Trading Commission’s LabCFTC released “A CFTC Primer on Smart Contracts” to provide information on a variety of financial...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent SEC No-Action, Re-Proposal for Security-Based Swaps Focus on Comparability With Other US Regulators

In recent days, the Securities and Exchange Commission (SEC) announced a no-action position on enforcing its 2016 Business Conduct Standards against security-based swap dealers (SBSDs) and major security-based swap...more

Shearman & Sterling LLP

US Prudential Regulators Amend Swap Margin Rule to Reflect QFC Stay Requirements

by Shearman & Sterling LLP on

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance Agency (together,...more

Orrick - Structured Finance Group

Agencies Approve Amendments to Swap Margin Rule

On September 21, the Farm Credit Administration, the FDIC, the Federal Housing Finance Agency, the Federal Reserve and the OCC approved final amendments to swap margin requirements to conform with recent rule changes that...more

White & Case LLP

The Delta Report - Derivatives Newsletter - July 2018: Securitisation Derivatives and the Margin Exemption

by White & Case LLP on

On 4 May 2018, the Joint Committee of the European Supervisory Authorities (ESAs) published a consultation paper on the draft regulatory technical standards (the Draft RTS) amending Delegated Regulation (EU) 2016/2251 on...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

Shearman & Sterling LLP

European Securities and Markets Authority Finalizes Guidelines on Anti-Procyclicality Margin Measures for CCPs

by Shearman & Sterling LLP on

The European Securities and Markets Authority has published a Final Report, setting out Guidelines for national regulators of CCPs on the application of rules under the European Market Infrastructure Regulation that require...more

Hogan Lovells

U.S. federal regulators propose amendments to swap margin regulations to clarify treatment of certain amendments to legacy swaps

by Hogan Lovells on

The Dodd-Frank Act requires entities that engage in swap activities to either submit their swaps for clearing with a central clearinghouse or to collect and post collateral (margin) based on the daily mark-to-market exposure...more

Dentons

CFTC proposes amendments to margin requirements for swaps for non–prudentially regulated swap dealers and major swap participants

by Dentons on

On May 23, 2018, the Commodity Futures Trading Commission (CFTC) published proposed amendments to its Margin Rule, which sets the margin requirements for uncleared swaps for swap dealers and major swap participants ("covered...more

Katten Muchin Rosenman LLP

Corporate & Financial Weekly Digest, Featuring Topics on Broker-Dealer, CFTC, Derivatives, Cryptocurrencies, GDPR, UK and EU...

by Katten Muchin Rosenman LLP on

BROKER-DEALER - FINRA Publishes Information Notice Regarding Enhancements to the Disclosure Review Process Relating to Public Financial Records - On May 18, the Financial Industry Regulatory Authority (FINRA) published...more

Shearman & Sterling LLP

US Federal Financial Regulators Propose Amendments to Swap Margin Rule

by Shearman & Sterling LLP on

The US Office of the Comptroller of the Currency, the US Board of Governors of the Federal Reserve System, the US Federal Deposit Insurance Corporation, the US Farm Credit Administration and the US Federal Housing Finance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC OCIE Examinations Announces 2018 Examination Priorities - On February 7, the Securities and Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") announced its 2018 examination...more

Orrick - Structured Finance Group

Agencies Seek Comment on Proposed Amendments to Swap Margin Rule

On February 5, five federal agencies (the Farm Credit Administration, FDIC, Federal Housing Finance Agency, Federal Reserve and Office of the Comptroller of the Currency) proposed to amend swap margin requirements to conform...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest, Featuring Topics on SEC/Corporate, Broker-Dealer, Derivatives and UK/EU Developments

by Katten Muchin Rosenman LLP on

SEC/CORPORATE - SEC Approves NYSE Rule to Facilitate Listing Without an IPO - On February 2, the Securities and Exchange Commissions approved a New York Stock Exchange (NYSE) rule change that facilitates the listing...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest, Featuring Topics on Broker-Dealer, Derivatives, CFTC and UK/Brexit/EU Developments

by Katten Muchin Rosenman LLP on

BROKER-DEALER - FINRA Requests Comment on Proposed Amendments to FINRA Rule 4521 and New Supplemental Liquidity Schedule On January 8, the Financial Industry Regulatory Authority (FINRA) requested comment on proposed...more

Shearman & Sterling LLP

European Supervisory Authorities Publish Final Draft Technical Standards Amending Margin Requirements for Non-Centrally Cleared...

by Shearman & Sterling LLP on

The Joint Committee of the European Supervisory Authorities has published a final report containing final draft Regulatory Technical Standards amending the requirements for risk-mitigation techniques for uncleared OTC...more

Dechert LLP

The European Supervisory Authorities (ESAs) publish final draft technical standards amending margin requirements for...

by Dechert LLP on

The ESAs published their co-authored draft Regulatory Technical Standards (RTS) on the 19 December 2017, amending the framework of the European Market Infrastructure Regulation (EMIR) in relation to physically settled foreign...more

Shearman & Sterling LLP

Financial Regulatory Developments Focus - December 2017

by Shearman & Sterling LLP on

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Shearman & Sterling LLP

EU Moves to Remove Physically-Settled FX Forwards from Variation Margin Requirements

by Shearman & Sterling LLP on

The Joint Committee of the European Supervisory Authorities has announced a review of the Regulatory Technical Standards under the European Market Infrastructure Regulation which include the requirement to exchange variation...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume XII, Issue 42

by Katten Muchin Rosenman LLP on

SEC/CORPORATE - SEC Division of Corporation Finance Issues C&DI Clarifying Exemptions for Non-GAAP Information in Forecasts for M&A Transactions - On October 17, the staff of the Securities and Exchange Commission’s...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC Comparability Determination on EU Margin Requirements and a Common Approach on Trading Venues - On October 13, 2017, the U.S. Commodity Futures Trading Commission ("CFTC") announced determinations by the CFTC and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and European Commission Make Progress on Cross-Border Agreements

On October 13, 2017, the Commodity Futures Trading Commission (CFTC) announced two cross-border developments with the European Commission (EC) that take significant steps toward reconciling regulation of cross-border...more

Orrick - Structured Finance Group

ISDA Launches SIMM 2.0 for Calculating Uncleared Swaps Initial Margin

On September 7, 2017, ISDA launched a new version of its standard initial margin model (SIMM), ISDA SIMM Version 2.0, which includes a full recalibration of risk factors as well as: New risk factors for three product...more

White & Case LLP

Reflections upon the proposed amendments to EMIR

by White & Case LLP on

Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories ("EMIR") entered into force on 16 August 2012. Most of the obligations...more

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