Insights & Publications
Diversity & Inclusion
© 2022 Debevoise & Plimpton LLP
Banking Agencies’ Guidance on Compliance Date for Uncleared Swap Margin Rules
24 February 2017
View Client Update
On February 23, 2017, the Federal Reserve Board (the “FRB”) and the Office of Comptroller of the Currency (the “OCC”) issued guidance on how banking supervisors should examine swap dealers for compliance with variation margin requirements.
The guidance explains that the variation margin compliance is expected as of March 1, 2017, with respect to the swap dealers and financial end users that present significant exposures.
However, with respect to other counterparties, the guidance explains that the examiners should focus instead on the swap dealers’ good faith efforts to comply with the requirements as soon as possible, and in no case later than September 1, 2017.
Structured Finance & Derivatives
Private Equity Firms and Funds
Regional & Other Practices
Emilie T. Hsu
UK Modern Slavery Act Transparency Statement
Debevoise Login (2)
Debevoise Women's Review