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Financial Markets Margin Requirements

Mayer Brown Free Writings + Perspectives

SEC Staff Issues Guidance on Rule 15c3-3a and Treasury Clearing

On August 6, 2025, the Staff of the Division of Trading and Markets of the Securities and Exchange Commission (SEC) released an updated set of Frequently Asked Questions (FAQs) addressing the application of Rule 15c3-3a to...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Extends Phase 5 Compliance Date for Its Initial Margin Rules and Proposes More Regulatory Flexibility for Non-US Commodity...

On May 28, 2020, the Commodity Futures Trading Commission (CFTC or Commission) unanimously approved an interim final rule extending the Phase 5 compliance date for the Commission’s initial margin rules (Interim Final Rule)...more

Hogan Lovells

Collateral issues for derivatives counterparties amid the COVID-19 pandemic

Hogan Lovells on

The current COVID-19 pandemic has led to huge disruption in financial markets and larger collateral swings.  This note sets out some issues market participants may need to consider in relation to collateral under OTC...more

Morgan Lewis

Global Standard Setters Extend Deadlines for Uncleared Margin Requirements

Morgan Lewis on

To help address market participants in the face of the coronavirus (COVID-19) crisis, the Basel Committee on Banking Supervision and the International Organization of Securities Commissions have provided a one-year extension...more

A&O Shearman

Options Clearing Corporation Enters Into Settlements With SEC And CFTC Over Risk Management Policies

A&O Shearman on

On September 4, 2019, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) announced they had entered into settlements with Options Clearing Corporation (“OCC”) regarding its...more

Hogan Lovells

U.S. federal regulators propose amendments to swap margin regulations to clarify treatment of certain amendments to legacy swaps

Hogan Lovells on

The Dodd-Frank Act requires entities that engage in swap activities to either submit their swaps for clearing with a central clearinghouse or to collect and post collateral (margin) based on the daily mark-to-market exposure...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC Comparability Determination on EU Margin Requirements and a Common Approach on Trading Venues - On October 13, 2017, the U.S. Commodity Futures Trading Commission ("CFTC") announced determinations by the CFTC and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC and European Commission Make Progress on Cross-Border Agreements

On October 13, 2017, the Commodity Futures Trading Commission (CFTC) announced two cross-border developments with the European Commission (EC) that take significant steps toward reconciling regulation of cross-border...more

Herbert Smith Freehills Kramer

Funds Talk: June 2017 - FINRA Expands Margin Rules for Mortgage-Backed Securities Transactions

FINRA has introduced an expansion of Rule 4210 (the Rule), effective Dec. 15, 2017, importing margin concepts into the world of mortgage-backed transactions. ...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Holland & Knight LLP

Guide to U.S. Variation Margin Documentation for Financial End Users

Holland & Knight LLP on

The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more

McGuireWoods LLP

ISDA Launches 2016 Variation Margin Protocol to Facilitate Compliance With Margin Rules

McGuireWoods LLP on

On August 16, 2016, the International Swaps and Derivatives Association, Inc. (ISDA) published the ISDA 2016 Variation Margin Protocol (VM Protocol). The VM Protocol will help market participants implement the new variation...more

Lowndes

Agencies Adopt Final Rule on Swap Margin Requirements

Lowndes on

The Office of the Comptroller of the Currency, Treasury (“OCC”), Board of Governors of the Federal Reserve System (“Board”), Federal Deposit Insurance Corporation (“FDIC”), Farm Credit Administration (“FCS”), and the Federal...more

Orrick, Herrington & Sutcliffe LLP

Derivatives in Review - April 2016

Novo Banco and CDS – A Post-Mortem - The 2014 ISDA Credit Derivatives Definitions updated the previous set of credit derivatives definitions to, among other things, include a credit event for “Governmental Intervention.”...more

Katten Muchin Rosenman LLP

Questions and Answers Concerning the Final Prudential Regulator Margin Rules for Non-Cleared Swaps

BACKGROUND - The five US prudential regulators for swaps (the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, the Comptroller of the Currency, the Farm Credit Administration and the...more

Orrick - Finance 20/20

Federal Reserve, OCC, FCA, FHFA and FDIC Adopt Joint Final Rule on Swap Margin Requirements

Orrick - Finance 20/20 on

On October 22, the Office of the Comptroller of the Currency (the “OCC”), the Federal Reserve Board (the “Board”), the Farm Credit Administration (the “FCA”), the Federal Housing Finance Agency (the “FHFA”), and the Federal...more

Cadwalader, Wickersham & Taft LLP

Prudential Regulators Release Final Margin Rules for Swaps

On October 22, 2015, the Federal Deposit Insurance Corporation held an open meeting at which it voted to adopt: (i) final rules governing margin and capital requirements for uncleared swaps and (ii) an interim final rule to...more

Stinson - Corporate & Securities Law Blog

Banking Regulators Adopt End-User Exemption for Swap Margin Requirements

New Margin Requirements - The Board of Directors of the Federal Deposit Insurance Corporation approved a final rule to establish margin requirements for swaps that are not cleared through a clearinghouse. This action is...more

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