News & Analysis as of

Office of the Comptroller of the Currency Swap Dealers Margin Requirements

Orrick - Finance 20/20

CFTC Approves a Final Rule to Amend Uncleared Swap Margin Requirements

Orrick - Finance 20/20 on

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

Morrison & Foerster LLP

The Federal Reserve and OCC Guidance Regarding Initial Examinations for Compliance with Variation Margin Rules for Non-Cleared...

Last week the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and the Office of the Comptroller of the Currency (the “OCC” and, collectively with the Federal Reserve, the “Banking Agencies”) released...more

Troutman Pepper

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

Troutman Pepper on

If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

McGuireWoods LLP

Swap Dealer Banks Win Six Month Phase-In for Variation Margin Requirements for Most Counterparties

McGuireWoods LLP on

U.S. swap dealer banks received much needed breathing room, but not complete relief from the March 1, 2017 variation margin (VM) deadline for swaps and security-based swaps. On February 23, 2017, the Federal Reserve Board...more

Stinson - Corporate & Securities Law Blog

Banking Regulators Adopt End-User Exemption for Swap Margin Requirements

New Margin Requirements - The Board of Directors of the Federal Deposit Insurance Corporation approved a final rule to establish margin requirements for swaps that are not cleared through a clearinghouse. This action is...more

Orrick - Finance 20/20

OCC Proposes Rule on Margin and Capital Requirements for Covered Swap Entities

Orrick - Finance 20/20 on

October 6, the OCC released a notice of proposed rulemaking to establish minimum requirements for the exchange of initial and variation margin between registered swap dealers, major swap participants, security-based swap...more

Orrick - Finance 20/20

Federal Agencies Seek Comment on Swap Margin Requirements

On September 3, the Fed, the Farm Credit Administration, the FDIC, the FHFA, and the OCC sought comment on a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap...more

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