Prudential Regulators and CFTC Re-Propose Margin Requirements for Non-Cleared Swaps

Skadden, Arps, Slate, Meagher & Flom LLP

Mark D. Young Maureen A. Donley Elizabeth A. Mastrogiacomo

Federal banking regulators and the CFTC have re-proposed regulations to require certain dealers and major participants in the swap and security-based swap markets to collect initial and variation margin for non-cleared swaps. The re-proposals make several significant changes to the proposed rules first issued by the regulators in 2011. This client alert answers some of the basic questions about the re-proposals, summarizes the proposed margin counterparty categories and gives an overview of how margin calculations would be made.

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