ASF Submits Comment Letter re Swap Margin Rules to CFTC
September 20, 2012
On September 20, ASF submitted our comment letter in response to the Commodity Futures Trading Commission’s (“CFTC”) April 28, 2011 notice of proposed rulemaking (“NPR”) regarding the establishment of minimum margin requirements for certain swap dealers and major swap participants issued pursuant to Title VII of the Dodd-Frank Act. In addition, ASF has also sent the letter to other entities with swap margin proposals, including the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Farm Credit Administration, Federal Housing Finance Agency, and Office of the Comptroller of the Currency (collectively, the “Prudential Regulators”), and the Basel Committee on Banking Supervision and the International Organization of Securities Commissions (“IOSCO”). Ellen Marks of Latham and Watkins LLP is serving as ASF’s outside counsel on this initiative.
ASF Comment Letter: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants - September 20, 2012
CFTC NPR: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants - April 28, 2011
CFTC Notice of Comment Period Extension: Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants - July 12, 2012
CFTC Fact Sheet: Proposed Rules Regarding Margin for Uncleared Swaps
CFTC Q&A: Proposed Rules Regarding Margin for Uncleared Swaps