Prudential Regulators And CFTC Re-Propose Margin Requirement Rules For Uncleared Swaps

The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency (collectively, the "Prudential Regulators") published proposed rules for public comment in the Federal Register on September 24, 2014, regarding margin requirements for uncleared swaps and security-based swaps applicable to entities subject to their jurisdiction (e.g., registered swap dealers and major swap participants that are U.S. or foreign banks). The proposal is available here. The Commodity Futures Trading Commission ("CFTC") followed suit, publishing its proposed margin rules for uncleared swaps entered into by entities subject to its jurisdiction (e.g., registered swap dealers and major swap participants that are not U.S. or foreign banks) on October 3, 2014. The CFTC's proposal is available here. The comment periods for the two rulemaking