Regulatory Alerts2015-07-14 | 2015-16718Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants-Cross-Border Application of the Margin Requirements
The Commodity Futures Trading Commission proposes rules to apply initial and variation margin requirements for uncleared swaps to cross-border transactions involving Swap Dealers and Major Swap Participants. The framework utilizes a hybrid, firm-wide approach that distinguishes applicability based on whether counterparties are U.S. persons or foreign consolidated subsidiaries, while also providing for substituted compliance and specific exclusions. These measures aim to mitigate systemic risk to the U.S. financial system by ensuring adequate collateralization of counterparty exposures across international jurisdictions.
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