Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants

概要

The Commodity Futures Trading Commission ("Commission" or "CFTC") is adopting amendments to the margin requirements for uncleared swaps for swap dealers ("SD") and major swap participants ("MSP") for which there is not a prudential regulator (the "CFTC Margin Rule"). Specifically, the CFTC Margin Rule mandated the collection and posting of variation margin and initial margin ("IM") under a phased compliance schedule extending from September 1, 2016, to September 1, 2020. The Commission is hereby amending the compliance schedule to further delay the compliance date for entities with smaller average daily aggregate notional amounts ("AANA") of swaps and certain other financial products (the "Smaller Portfolio Group") from September 1, 2021, to September 1, 2022, to avoid market disruption due to the large number of entities being required to comply by September 1, 2021, as a result of the adoption of the interim final rule ("Final Rule").