Regulatory Alerts2016-01-06 | 2015-32320Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
The Commodity Futures Trading Commission adopted final rules establishing initial and variation margin requirements for uncleared swaps between swap dealers and major swap participants. These regulations implement Section 4s(e) of the Commodity Exchange Act as amended by the Dodd-Frank Act, while explicitly exempting non-financial end users from margin collection obligations. The Commission also issued an interim final rule exempting certain uncleared swaps from these requirements to comply with the Terrorism Risk Insurance Program Reauthorization Act of 2015.
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