Search Results for: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants

CFTC Extends No-Action Relief to Swap Dealers in Connection with Swaps Subject to EMIR Margin Requirements

  On April 18, 2017, the Commodity Futures Trading Commission (“CFTC”) issued a no-action letter extending until November 7, 2017 the relief provided under CFTC Letter No. 17-05 (“Letter 17-05”), which was scheduled to expire on May 8, 2017.[1]  Letter 17-05 provides relief from certain CFTC margin requirements to certain swap dealers (“SDs”) in connection […]

CFTC Issues Swap Dealer De Minimis Exception Preliminary Report

  On November 18, 2015, the Commodity Futures Trading Commission (“CFTC”) issued for public comment the Swap Dealer De Minimis Exception Preliminary Report (the “Preliminary Report”).[1]  The de minimis exception from the swap dealer (“SD”) registration requirement currently provides an $8 billion threshold (in aggregate gross notional swap dealing activity measured over the prior 12-month […]

CFTC Proposes Cross-Border Framework for Application of Margin Rules

  In July, the CFTC proposed a rule for the application of its uncleared swap margin requirements to cross-border swap transactions.[1]  The CFTC recognized that a cross-border framework for margin “necessarily involves consideration of significant, and sometimes competing, legal and policy considerations.”  However, in developing the proposed rule, it noted that it was attempting to […]

Dodd-Frank Implementation Update

  Title VII of the Dodd-Frank Act,[1] titled the “Wall Street Transparency and Accountability Act of 2010” (the “Act”), was enacted on July 21, 2010. Under the Act, which is generally intended to bring the $600 trillion over-the-counter derivatives market under greater regulation, the Commodity Futures Trading Commission (“CFTC”) will have primary responsibility for the […]