On December 20, ISDA published the tokenized collateral model provisions for inclusion in ISDA 2016 Credit Support Annexes for Variation Margin (VM) (the “Model Provisions”). The Model Provisions comprise two sets of...more
Earlier this month, the ESAs published a final report on proposed updates to the existing EMIR margin rules (the “Margin RTS Updates”). Although not yet final, the absence of a public consultation and fast approaching...more
This updated guide lays out the margin requirements for uncleared derivative transactions in a user-friendly comparative table. ...more
On October 1, 2018, Chairman J. Christopher Giancarlo of the Commodity Futures Trading Commission ("CFTC") published a white paper entitled "Cross-Border Swaps Regulation Version 2.0: A Risk-Based Approach with Deference to...more
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
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
A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details of the FCA’s stance on the reporting of cyber attacks; the Government’s opinion on...more
On October 12, 2017, the Division of Clearing and Risk (Division) of the US Commodity Futures Trading Commission (CFTC) issued an interpretative letter in response to a request for clarification on whether payments of...more
FINRA has introduced an expansion of Rule 4210 (the Rule), effective Dec. 15, 2017, importing margin concepts into the world of mortgage-backed transactions. ...more
CME and LCH Amend Rulebooks on Variation Margin - Market participants historically have characterized cleared derivatives as being "collateralized-to-market", treating variation margin transfers as daily collateral...more
Following the Basel Committee on Banking Supervision and the International Organization of Securities Commissions' March 18, 2015, release of revisions to the framework for margin requirements for non-centrally cleared...more
CFTC Indicates Willingness to Help Incubate Fintech - On February 21, 2017, J. Christopher Giancarlo, the acting chairman of the U.S. Commodity Futures Trading Commission ("CFTC"), has diverged from other U.S. federal...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