U.S. Prudential Regulators Finalize Uncleared Derivative Margin Rules

FDIC and OCC Approve Long Awaited Final Rule

Earlier this year, Derivative Path sent out a Regulatory Update regarding a bill passed by Congress providing regulatory relief from anticipated uncleared swap margin rules for non-financial end users and other counterparties eligible for an end user exception.  The legislation amended Dodd-Frank, exempting certain transactions from future initial and variation margin requirements, while requiring regulators to promulgate a final rule on margin requirements.

On October 22, 2015, the FDIC and OCC released a joint final rule in conjunction with other U.S. prudential regulators on swap margin requirements, ending a long period of uncertainty and delivering what should be welcome relief to community and regional banks and their hedging clients.

We provide a detailed analysis of the rule, its applicability to regional and community banks, commercial end users, and what to look for in the next several months.  We also provide a simple grid of important dates for various counterparties.

FDIC and OCC Approve Long Awaited Final Rule

Earlier this year, Derivative Path sent out a Regulatory Update regarding a bill passed by Congress providing regulatory relief from anticipated uncleared swap margin rules for non-financial end users and other counterparties eligible for an end user exception.  The legislation amended Dodd-Frank, exempting certain transactions from future initial and variation margin requirements, while requiring regulators to promulgate a final rule on margin requirements.

On October 22, 2015, the FDIC and OCC released a joint final rule in conjunction with other U.S. prudential regulators on swap margin requirements, ending a long period of uncertainty and delivering what should be welcome relief to community and regional banks and their hedging clients.

We provide a detailed analysis of the rule, its applicability to regional and community banks, commercial end users, and what to look for in the next several months.  We also provide a simple grid of important dates for various counterparties.

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