On June 25, the five prudential regulators responsible for the margin rules for bank swap dealers (the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration and the Federal Housing Finance Agency) adopted one final rule and one interim final rule that modify their original framework for margining uncleared swaps.
Continue Reading Prudential Regulators Revise Initial Margin Rules for Uncleared Swaps

Katten hosts a weekly, 15-minute fireside chat podcast series on notable UK and European developments from the prior week’s Corporate & Financial Weekly Digest. This week, Carolyn Jackson speaks on the obligation of financial counterparties (FCs) to mandatorily report OTC derivatives transactions on behalf of their non-financial counterparties (NFCs)-counterparties commencing June 18, 2020; Nathaniel

On May, 27, the Alternate Reference Rate Committee (ARRC) that works under the auspices of the Federal Reserve Bank of New York issued a set of “Best Practices for Completing Transition Away from LIBOR.” The Best Practices reinforce the ARRC’s position that markets should cease using the London Inter-bank Offered Rate (LIBOR) as a reference rate in financial transactions well before the December 31, 2021 end date identified by UK regulators by providing specific dates by which specific products should be LIBOR-free.
Continue Reading LIBOR Transition Best Practices Statement Issued by ARRC

On May 22, the Financial Industry Regulatory Authority (FINRA) issued an open invitation for member firms and other interested parties to provide views and information about the security-based swap (SBS) market, with particular focus on broker-dealer SBS activities and the application of FINRA rules to those activities. The invitation, which is not a mandatory information request, includes the following questions:
Continue Reading FINRA Requests Comments on Security-Based Swaps

On May 19, the National Futures Association (NFA) submitted to the Commodity Futures Trading Commission proposed technical amendment to several of NFA’s Rules and Interpretive Notices. In addition to correcting numerous cross-references and eliminating obsolete provisions, the proposed technical amendments add a definition of Swap Execution Facility (SEF) to NFA Compliance Rule 1-1 and require

On May 19, the Commodity Futures Trading Commission’s Global Markets Advisory Committee approved a report that contains several recommendations for action by the CFTC with respect to the implementation of its initial margin (IM) rules for uncleared swaps. The recommendations are focused on the unique challenges faced by small end users of swaps and entities that engage in swap activity through separate managed accounts (SMAs).
Continue Reading CFTC GMAC Recommendations Concerning Initial Margin for Swaps

The International Swaps and Derivatives Association, Inc. (ISDA) has launched a new webpage containing information about interest rate benchmark reform and the transition away from the use of interbank offered rates (IBORs, including LIBOR) as floating rates in swap transactions. The page and subsequent materials are available to everyone, not just ISDA members.
Continue Reading ISDA Launches Benchmark Reform Information Source