Key takeaways

• On February 13, 2017, the Division of Swap Dealer and Intermediary Oversight of the CFTC issued two no-action letters regarding the application of the CFTC’s margin requirements for uncleared swaps.
• The first letter provides no-action relief to swap dealers to delay, until September 1, 2017, full compliance with the variation margin requirements for uncleared swaps that are otherwise scheduled to go into compliance on March 1, 2017.
• The second letter  provides no-action relief to apply a “minimum transfer amount” no greater than $50,000 to the initial and variation margin amounts applicable to uncleared swaps entered into with “separately managed accounts.”