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ARTICLE · 18 AUGUST 2020

CFTC Proposes Amendments To Uncleared Swap Margin Rules

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The CFTC issued two separate proposals to amend the uncleared swap margin requirements.

United StatesFinance and Banking
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The CFTC issued two separate proposals to amend the uncleared swap margin requirements. The first proposal makes changes related to initial margin ("IM"), including (i) the calculation period for determining whether IM requirements apply, and (ii) permitting certain swap dealers ("SDs") to rely on models used by SD counterparties for limited purposes. The second proposal would primarily codify prior no-action relief related to the application of rules on minimum transfer amounts ("MTA").

IM Proposal. The proposal would amend the definition of "material swap exposure" in CFTC Rule 23.151 ("Definitions applicable to margin requirements") to provide that the calculation would take place as of September 1 of a year, and would look to month-end activities over March to April of that year. (The current rule provides for June to August of the prior year and looks to daily amounts rather than month-end.) The CFTC indicated that these changes were intended to align with the

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