Regulators Re-Propose Uncleared Swap Margin, Capital and Segregation Rules for Swap Entities
Client Memorandum

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On September 3, 2014, U.S. banking regulators re-proposed margin, capital and segregation requirements applicable to swap entities  for uncleared swaps.   The new proposed rules modify significantly the regulators’ original 2011 proposal in light of the Basel Committee on Banking Supervision’s and the International Organization of Securities Commissions’ (“BCBS/IOSCO”) issuance of their 2013 final policy framework on margin requirements for uncleared derivatives and the comments received on the original proposal.