Preparing for U.S. Uncleared Swap Margin Rules

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compliancereporter.com, Vol. XXIII, No. 6, March 21, 2016

This article first appeared in Compliance Reporter.

Under rules recently adopted by the U.S. banking regulators and Commodity Futures Trading Commission, registered swap dealers (SDs) will soon need to comply with margin collection, posting, segregation and documentation requirements. SDs that enter into uncleared swaps and—under the banking regulators’
rules—security-based swaps (collectively, “swaps”) will need to engage in extensive preparation during the months leading up to the first compliance deadline, which is Sept. 1, 2016 for the largest counterparty pairs.