CFTC's Proposed Margin Rules For Uncleared Swaps – America's Next Top Model

This is the fourth article in a series on the U.S. Commodity Futures Trading Commission's (CFTC's) proposed margin rules for uncleared swaps, with a particular focus on the rules as they relate to swap market participants that are neither swap dealers nor commercial end users.

Our first installment on the CFTC's proposed margin rules (Margin Rules) for uncleared swaps addressed the importance of the "financial end user" definition and making certain notional calculations. Our second and third installments addressed certain collateral requirements and the custody of initial margin. In this fourth and penultimate installment, we turn to the calculation of margin and related issues. Managing resources and capital meaningfully requires financial end users, as entities that will be exchanging margin with covered swap entities (CSEs), to understand how CSEs may be required to calculate margin.