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Email On April 12, 2011, the Commodity Futures Trading Commission ("CFTC") voted 4-1 to issue proposed rules establishing minimum initial and variation margin requirements for non-cleared swaps entered into by CFTC-regulated swap dealers and major swap participants. Later the same day, the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration and the Federal Housing Finance Agency(collectively, "Prudential Regulators") jointly issued their own rules establishing margin requirements for swap dealers and major swap participants that are subject to their respective prudential regulation. https://www.cadwalader.com/resources/clients-friends-memos/cftc-prudential-regulators-propose-margin-rules-for-non-cleared-swaps