Prepare Now For A New Swaps Margin Regime

Law360, New York (November 12, 2015, 10:40 AM EST) -- Joshua Cohn

Curtis A. Doty On Oct. 22, 2015, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corp., the Farm Credit Administration and the Federal Housing Finance Agency (collectively, the "agencies") adopted (1) a joint final rule[1] to establish minimum margin requirements for registered swap dealers, major swap participants, security-based swap dealers and major security-based swap participants (collectively, "swap entities") for which one of the agencies is the prudential regulator[2] ("covered swap entities" or "CSEs") and (2) a companion interim final rule[3] (and request for comment) to implement...

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