• CFTC and Prudential Regulators Propose Margin Requirements for Uncleared Swaps
  • May 2, 2011 | Authors: Bruce C. Bennett; William L. Massey; Philipp Tamussino
  • Law Firms: Covington & Burling LLP - New York Office ; Covington & Burling LLP - Washington Office ; Covington & Burling LLP - New York Office ; Covington & Burling LLP - Washington Office ; Covington & Burling LLP - New York Office
  • The Commodity Futures Trading Commission (“CFTC”) and banking regulators voted recently to propose margin requirements for uncleared swaps under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). The rules issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency (collectively, the “prudential regulators”) will apply to swap dealers and major swap participants (collectively, “swap entities”) that are banks regulated by these agencies. The rules issued by the CFTC will apply to non-bank swap entities.