Client Alert

The Dodd-Frank Wall Street Reform and Consumer Protection Act intends that all swap dealers, major swap participants, security-based swap dealers and security-based major swap participants be subject to rules on minimum margin for all swaps and security-based swaps not cleared by a registered central clearing house. The Federal Reserve, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration, and the Federal Housing Finance Agency, the Commodity Futures Trading Commission and the Securities and Exchange Commission have been tasked with promulgating these rules.

The Prudential Regulators first proposed a rule in April 2013 to deal with Uncleared Swap margin and then re-proposed the rule in September 2014 to reflect the international guidelines for uncleared margin put forth by the Basel Committee of Banking Supervision and the International Organization of Securities Commissions in September 2013. On October 22, 2015, the FDIC, the OCC and the Farm Credit Administration approved a final rule establishing margin requirements for Uncleared Swaps and the Federal Reserve and Federal Housing Finance Agency followed suit on October 30. The Final Rule becomes effective on April 1, 2016.

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