By Stephen A. Keen & Andrew P. Cross

In this, the twelfth installment of our review of the compliance requirements of new Rule 18f‑4, we leave the peripheral transactions addressed in the rule (i.e., delayed-delivery transactionsreverse repurchase agreements, and unfunded commitment agreements) and plunge into the core of the rule: “derivatives

FINRA recently submitted a filing with the SEC that will effectively delay the mandatory margining of TBAs pursuant to FINRA Rule 4210 until October 26, 2021.   In that filing, FINRA indicated that it is considering whether there should be additional revisions to FINRA Rule 4210 (i.e., beyond those that are now scheduled to go into

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

The short answer is it is not clear, but we do not expect the new margin rules to apply to trades any earlier than June 2016 or later than January 2018, assuming that the proposed rules are approved by the SEC.  Although, we recommend that market participants consider dealing with any open negotiations of Master Securities Forward Transaction Agreements (MSFTAs) and re-papering of existing MSFTAs well in advance of the actual implementation date.

The remainder of this posting will deal with the mechanics and procedures behind the determination of these dates and provide our readers with additional information in respect of our recommendation to “dust off” their MSFTA files sooner rather than later.
Continue Reading When Will FINRA’s New TBA Margin Proposal Go Into Effect and Be Implemented?