2019-04-01 | 2019-06103The Commodity Futures Trading Commission adopted an interim final rule to address potential disruptions to uncleared swap margin requirements resulting from a no-deal Brexit. The amendment ensures that legal transfers of legacy swaps executed prior to compliance dates retain their legacy status and remain exempt from initial and variation margin requirements when transferred in connection with Brexit planning. This relief allows swap dealers and major swap participants to restructure their portfolios without triggering new margin obligations for the affected transactions.