Category: End-User Exception

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A Marginally Important Day: FDIC’s Board Approves Joint Final Rule on Margin for Uncleared Swaps and Finalizes Relief for End-Users

Earlier today, the Board of Directors (the “Board”) of the Federal Deposit Insurance Corporation (FDIC) approved a final rule to establish margin requirements on non-cleared swaps and security-based swaps (collectively, for this posting, “non-cleared swaps”).  The FDIC is issuing the rule jointly with the OCC, the board of the Federal Reserve,… Continue Reading

Attention Corporate Treasurers and Swap Provider Banks: CFTC Updates End-User Exception For Treasury Affiliates

On November 26th, the Division of Clearing and Risk (the “Division”) of the Commodity Futures Trading Commission (“CFTC”) published No-Action Letter 14-144 (also referred to as “CFTC Letter 14-144”), in order to update the conditions that must be satisfied by corporate end-users to avail themselves of “treasury affiliate relief” from the central clearing and trade execution … Continue Reading