ARTICLE
18 November 2019

Federal Register: Prudential Regulators Propose Amendments To Swap Margin Rules - December 9, 2019

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
U.S. prudential regulators proposed rule amendments governing margin requirements for uncleared swaps and security-based swaps.
United States Finance and Banking

U.S. prudential regulators proposed rule amendments governing margin requirements for uncleared swaps and security-based swaps. The proposed rule amendments were published in the Federal Register. Comments on the proposal must be submitted by December 9, 2019.

As previously covered, the proposal would make five substantive changes to the margin rules: (i) removal of inter-affiliate initial margin, (ii) amendments to permit changes to "legacy" swaps relating to benchmarks, (iii) extension of the compliance period for initial margin, (iv) permission of non-material amendments to "legacy" transactions and (v) clarification regarding documentation requirements when initial margin is not exchanged due to the $50 million threshold.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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