A Buy-Side Guide to Regulatory and Transactional Issues Related To Derivatives and Repurchase Agreements
Short Answer
Yes, for all intents and purposes.
Explanation
The administrative process related to the deferral of Rule 4210 has become a perennial source of confusion, given the perennial deferral of margining on to-be-announced securities (or what can be described as the delayed delivery of margin on TBAs (pun intended), not that anybody is complaining about these deferrals).
So, we have distilled this administrative process down to a few bullet points:…
By Stephen A. Keen and Andrew P Cross
This post is the second installment of our discussion of the compliance requirements of new Rule 18f-4.
The comments on proposed Rule 18f-4 revealed a significant lacuna in the rule resulting from two unrelated changes to current regulations. First, the SEC will rescind Investment Company Act Release…
FINRA has recently submitted a filing with the Securities and Exchange Commission (“SEC”) to propose another delay to the implementation of TBA margin requirements under Rule 4210. The new implementation date would be March 25, 2021.
FINRA has requested that the deferred implementation date becomes effective immediately upon filing of the rule change by FINRA with the SEC. …
Continue Reading FINRA Rule 4210 Update: FINRA Proposes To Delay TBA Margining (Again) Until March 25, 2021
FINRA has made it official. Earlier today, FINRA published Regulatory Notice 19-05, delaying TBA margin requirements until March 25, 2020. FINRA explained:
FINRA is issuing this Notice to announce that FINRA is extending by an additional year, until March 25, 2020, the effective date of the margin requirements that otherwise would have become effective…
On January 29th, FINRA released the following statement:
Financial Industry Regulatory Authority, Inc. (“FINRA”) is filing with the Securities and Exchange Commission (“SEC” or “Commission”) a proposed rule change to extend, to March 25, 2020, the implementation date of the amendments to FINRA Rule 4210 (Margin Requirements) pursuant to SR-FINRA-2015-036, other than the amendments pursuant to SR-FINRA-2015-036 that were implemented on December 15, 2016.
FINRA has indicated that it will file the proposed rule change with the Securities and Exchange Commission (“SEC”) with a request for “immediate effectiveness,” which means that FINRA is recommending to the SEC that the deferred implementation date will become effective immediately upon filing of the rule change by FINRA with the SEC. …
Continue Reading FINRA Rule 4210 Update: New Proposed Implementation Date of March 25, 2020 for TBA Margining
On September 19, 2017, the Financial Industry Regulatory Authority (“FINRA”) published a proposed rule change (available here) to delay implementation of certain margin requirements in respect of what are referred to as “Covered Agency Transactions,” including To Be Announced (“TBA”) transactions and other specified delayed delivery transactions involving mortgage-backed securities.
The delay will move the implementation date of the margin requirements from December 15, 2017 until June 25, 2018. …
Continue Reading FINRA Publishes Proposed Rule Change to Delay Implementation of TBA Margining Until June 25, 2018
