Summary Of Prudential Regulators' Re-Proposed Margin Rules

On September 3, the Board of Governors of the Federal Reserve System ("Board"), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance Agency (collectively, the "Prudential Regulators") voted to re-propose rules to implement Sections 731 and 764 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") (a draft of which has been published online – the "Draft Proposal").¹  The Draft Proposal would impose initial and variation margin requirements on prudentially regulated swap dealers, security-based swap dealers, major swap participants and major security-based swap participants ("Covered Swap Entities") entering into uncleared swaps and security-based swaps.