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Swap Dealers › Uncleared Swaps

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 -
Proskauer Rose LLP

CFTC Proposes Changes to Margin Requirements for Uncleared Swaps

Proskauer Rose LLP on

On July 26, 2023, the CFTC approved a proposal to amend the margin regulations for uncleared swaps (the “Proposed Amendments”). The Proposed Amendments, if finalized, would relieve registered swap dealers and major swap...more

Sheppard Mullin Richter & Hampton LLP

Security-Based Swap Rules for End-Users

Sheppard Mullin Richter & Hampton LLP on

As of November 1, 2021, dealers in security-based swaps (“SBS”) whose dealing activity exceeds certain de minimis thresholds (e.g., gross notional amount of $3 billion for credit default SBS, $150 million for other SBS, and...more

A&O Shearman

CFTC Approves Final Rule on Post-Trade Name Give-Up on Swap Execution Facilities

A&O Shearman on

The CFTC has adopted a final rule to prohibit the controversial practice of post-trade name give-up for swaps that are executed anonymously through a Swap Execution Facility (SEF) and are intended to be cleared. Although the...more

WilmerHale

The SEC Adopts Security-Based Swap Rules Governing Risk Mitigation Techniques for Uncleared Security-Based Swaps

WilmerHale on

On December 18, 2019, the Securities and Exchange Commission (the SEC or Commission) adopted new rules pursuant to Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requiring the...more

K&L Gates LLP

Final Phase of Initial Margin Requirements for Uncleared Swaps to Be Delayed Until September 2021 for Most Market Participants–How...

K&L Gates LLP on

SUMMARY - Swap dealers (“SDs”) are required to post and collect initial margin (“IM”) for uncleared swaps with other SDs and counterparties that are financial end users with “material swap exposure” (“MSE”) in accordance...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and European Commission Make Progress on Cross-Border Agreements

Skadden, Arps, Slate, Meagher & Flom LLP on

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

K&L Gates LLP

Regulators Provide Guidance on Variation Margin for Uncleared Swaps; CFTC Also Delays Compliance Date for Filing Notices to...

K&L Gates LLP on

Global regulators adopted regulations to govern the posting and collection of margin on uncleared swaps. These regulations are set to take effect in stages over a four-year period. The initial compliance date was September...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Finalizes Cross-Border Margin Rules for Uncleared Swaps

Skadden, Arps, Slate, Meagher & Flom LLP on

On May 24, 2016, the Commodity Futures Trading Commission (CFTC) adopted final rules (cross-border margin rules) that specify how its recently issued uncleared margin rules apply to cross-border transactions. Chairman Timothy...more

Akerman LLP

Mandatory Margin Posting Regulations Coming Soon for Uncleared Swaps

Akerman LLP on

U.S. bank regulators recently adopted final rules establishing initial and variation margin requirements for uncleared swaps (Final Margin Rules). These rules apply to regulated entities such as banks and subsidiaries of bank...more

Dechert LLP

CFTC Approves Final Rule on Margin Requirements for Uncleared Swaps

Dechert LLP on

The U.S. Commodity Futures Trading Commission (CFTC) approved on December 16 final rules (Final Rules) on margin requirements for over-the-counter uncleared swaps entered into by CFTC-registered swap dealers (SDs) and major...more

Katten Muchin Rosenman LLP

Financial Regulators Adopt Final Margin Rules for Non-Cleared Swaps

Katten Muchin Rosenman LLP on

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

McGuireWoods LLP

Financial Entity Update: The CFTC’s Proposed Margin Rules for Uncleared Swaps – Know Thyself

McGuireWoods LLP on

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

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