Insights & Publications
Diversity & Inclusion
© 2020 Debevoise & Plimpton LLP
CFTC No-Action Letters on Uncleared Swap Margin Rules
15 February 2017
View Client Update
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.”
Structured Finance & Derivatives
Private Equity Firms and Funds
Emilie T. Hsu
UK Modern Slavery Act Transparency Statement
Debevoise Login (2)
Debevoise Women's Review