Several industry associations provided comments on a U.S.
prudential regulators' proposal to amend swap margin rules.
As previously covered, the amendments were
proposed by the FDIC, Federal Reserve Board ("FRB"), Farm
Credit Administration, Federal Housing Finance Agency and OCC
(collectively, the "Prudential Regulators") and 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.
