In Consultation Paper 13/23 (CP 13/23), the UK’s Prudential Regulation Authority (“PRA”) sets out its “Margin requirements for non-centrally cleared derivatives: Amendments to BTS 2016/2251.”...more
The Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) have published a Consultation Paper1 with proposed changes to the secondary rules regarding margin requirements applicable to non-centrally...more
On February 27-28th, the Basel Committee on Banking Supervision met to discuss policy and supervisory issues, and the extent to which members had implemented post-financial crisis reforms....more
The Commodity Futures Trading Commission has unanimously approved an interim final rule that will allow swap dealers and major swap participants to, in the event of a no-deal Brexit scenario, transfer legacy swaps entered...more
BROKER-DEALER - FINRA Proposes Data Service for Corporate Bond New Issues - The Financial Industry Regulatory Authority (FINRA) has filed with the Securities and Exchange Commission a proposed rule change to establish a...more
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
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 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
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
On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol is intended as a tool to help market participants that will...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
While the US gears up for compliance with uncleared swap margin rules, cross-border application of the CFTC rules remains unclear. The US Commodity Futures Trading Commission (the CFTC) finalized its margin requirements...more
On December 16, 2015, the Commodity Futures Trading Commission (“CFTC” or “Commission”) adopted final rules to impose margin requirements on uncleared swaps entered into by swap dealers and major swap participants subject to...more
While the rules provide some clarity, the global market still awaits the finalization of the CFTC and the European margin rules. With the clock ticking on the countdown to finalization of uncleared swap margin rules...more
The US prudential regulators (the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance Agency)...more
Federal banking regulators (Prudential Regulators) have finalized much-anticipated rules (Final Rules) relating to initial and variation margin requirements for certain swaps and security-based swaps that are not centrally...more
On October 22, the US prudential regulators (the Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve, Comptroller of the Currency, Farm Credit Administration and Federal Housing Finance Agency)...more
Our first installment on the CFTC’s proposed margin rules (Margin Rules) for uncleared swaps addressed the importance of the “financial end user” definition and making certain notional calculations. Our second and third...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
The CFTC has proposed rules that would define the reach of Dodd-Frank Act margin requirements in cross-border swap transactions. On June 29, 2015, the US Commodity Futures Trading Commission (CFTC) proposed regulations...more
The Commodity Futures Trading Commission (CFTC) recently proposed rules1 to address the cross-border application of margin requirements for uncleared swaps for swap dealers and major swap participants not subject to...more
On June 29, 2015, the Commodity Futures Trading Commission (“CFTC”) issued proposed rules (“Proposed Rules”) regarding the cross-border application of its proposed uncleared swaps margin rules issued last October. The...more
On January 8, 2015, the U.S. Senate approved legislation, by a 93-4 vote, to reauthorize the Terrorism Risk Insurance Act (“TRIA”). The legislation, dubbed the Terrorism Risk Insurance Program Reauthorization Act of 2015 (the...more
Dealers and major industry participants may be subject to new margin requirements beginning as early as December 1, 2015. Regulators are expected to finalize rules regarding margin requirements for uncleared swaps...more