The CFTC proposal to implement an alternative compliance
framework for the inter-affiliate swaps clearing exemption was published in the Federal Register. Comments on
the proposal must be submitted by February 21, 2020.
As previously covered, the CFTC unanimously
approved a proposal that would implement an alternative compliance
framework for the inter-affiliate swaps clearing exemption.
According to the CFTC, the proposal would amend CFTC Rule 50.52 to "reinstate the expired
alternative compliance frameworks for the inter-affiliate swaps
clearing exemption, with minor revisions to reflect the current
variation margining practices of affiliated counterparties electing
the exemption." The CFTC indicated that the proposal would (i)
codify staff no-action letters providing exceptions and (ii) offer
the two alternative compliance frameworks to associated entities
permanently.