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On September 17, 2014, the Commodity Futures Trading Commission (“CFTC”) voted to re‑propose rules to impose initial and variation margin requirements on uncleared swaps entered into by swap dealers and major swap participants that are not regulated by a “Prudential Regulator” (such entities, the “Covered Swap Entities”). The CFTC vote comes two weeks after the Prudential Regulators voted to re-propose analogous rules for swap dealers and major swap participants under their jurisdiction (the “PR Margin Proposal”). According to the discussion at the CFTC’s open meeting, the CFTC proposal – the text of which has not yet been made publicly available – is expected to be substantially similar to the PR Margin Proposal.