• The Deadline for Compliance with US Variation Margin Rules Has Been Extended - Are you Ready, Yet?
  • May 31, 2017 | Authors: James M. Cain; Meltem F. Kodaman; Raymond A. Ramirez
  • Law Firm: Eversheds Sutherland (US) LLP - Washington Office
  • Journal of Taxation and Regulation of Financial Institutions

    Compliance with US bank regulator and Commodity Futures Trading Commission rules requiring variation margin to be posted and collected for over-the-counter swap transactions between swap dealers and financial end-users will be required no later than September 1, 2017. Swap dealers will be unable to trade over-the-counter swaps with financial end-users absent mutual compliance with the new rules. 

    Compliance with the new requirements will necessitate changes to existing trade documentation and collateral management practices. In their article for the Journal of Taxation and Regulation of Financial Institutions, Eversheds Sutherland (US) attorneys James Cain, Meltem Kodaman and Raymond Ramirez provide an overview of the variation margin rule and methods for compliance.