News & Analysis as of

Swap Dealers International Swaps and Derivatives Association Major Swap Participants

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
Holland & Knight LLP

Insurance Companies Need to Prepare for Swap Margin Rules in Effect on March 1, 2017

Holland & Knight LLP on

March 1, 2017, is the scheduled implementation date applicable for all insurance companies for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules. Although the...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

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

Wilson Sonsini Goodrich & Rosati

CFTC Extends Deadline to Comply with Certain Trading Documentation Requirements Under Dodd-Frank for Corporate End-Users of...

In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more

Foley Hoag LLP

Swap Users Take Note: March 2013 DF Protocol Deadline is July 1, 2013

Foley Hoag LLP on

Investment advisers with clients (including funds or separate accounts) that use swaps are reminded to have such clients sign up to the ISDA March 2013 DF Protocol (the “March DF Protocol”) by July 1, 2013....more

Eversheds Sutherland (US) LLP

Legal Alert: ISDA Accepting Comments on Draft Dodd-Frank "Protocol 2.0"

Pursuant to Title VII of the Dodd-Frank Wall Street Reform and Customer Protection Act (Dodd-Frank), the Commodity Futures Trading Commission (CFTC) has adopted a number of final regulations that require swap dealers (SDs)...more

Eversheds Sutherland (US) LLP

CFTC Extends Compliance Dates for Dodd-Frank Requirements Necessitating Amendments to Existing Trade Documentation

On December 18, the Commodity Futures Trading Commission (CFTC), by private vote, adopted interim final rules (Interim Final Rules) to amend the compliance dates for previously issued final rules that establish external...more

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