CFTC Issues Proposed Rules on Cross-Border Uncleared Swap Margin Requirements | White & Case LLP International Law Firm, Global Law Practice
CFTC Issues Proposed Rules on Cross-Border Uncleared Swap Margin Requirements

CFTC Issues Proposed Rules on Cross-Border Uncleared Swap Margin Requirements

On October 3, 2014, the Commodity Futures Trading Commission (the "CFTC") adopted and made public for comment proposed rules and accompanying interpretive guidance (the "Uncleared Swap Margin Proposing Release") setting forth the initial and variation margin requirements applicable to uncleared swaps. Included in the Uncleared Swap Margin Proposing Release was an Advanced Notice of Rulemaking regarding the application of the CFTC’s initial and variation margin requirements to cross-border swap transactions, which included a description of three separate methodologies the CFTC was considering.

On June 29, 2015, the CFTC adopted and made public for comment proposed rules (the "Proposed Cross-Border Rules") and accompanying interpretative guidance to more fully address the application of the CFTC's initial and variation margin requirements to cross-border swap transactions.

This Client Alert outlines the important concepts and consequences of the Proposed Cross-Border Rules, including the application of the CFTC’s initial and variation margin requirements to cross-border swap transactions as well as the CFTC’s proposed approach to substituted compliance determinations.

 

Click here to download the PDF.

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