In 2016, the Financial Industry Regulatory Authority announced the Securities and Exchange Commission’s approval of a rule change to establish margin requirements for Covered Agency Transactions. These transactions include (1) To Be Announced transactions, inclusive of adjustable rate mortgage transactions; (2) Specified Pool Transactions; and (3) transactions in Collateralized Mortgage Obligations, issued in conformity with a program of an agency or Government-Sponsored Enterprise, with forward settlement dates. Katten provided coverage of the rule amendments in the September 22, 2017 edition of Corporate & Financial Weekly Digest.

The new requirements will now take effect on March 25, 2019. Previously, the requirements were scheduled to go into effect on June 25, 2018.

For more information, please see Regulatory Notice 18-18, which is available here