On May 24, 2016, the Commodity Futures Trading Commission (CFTC) released final rules and accompanying interpretative guidance setting forth 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 these final rules, including the application of the CFTC's initial and variation margin requirements to cross-border swap transactions as well as the CFTC's approach to substituted compliance determinations.
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