The Federal Reserve Board ("FRB"), Farm Credit
Administration, Federal Housing Finance Agency and OCC
(collectively, "the Agencies") proposed rule amendments governing margin
requirements for uncleared swaps and security-based swaps. As
previously covered, the FDIC approved the proposal in
September.
The proposal would make five substantive changes to the margin
rules: (i) removal of inter-affiliate initial margin, (ii)
amendments to permit changes to "legacy" swaps relating
to benchmarks, (iii) extension of the compliance period for initial
margin, (iv) permission of non-material amendments to
"legacy" transactions and (v) clarification regarding
documentation requirements when initial margin is not exchanged due
to the $50 million threshold.