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ISDA responded to the Basel Committee on Banking Supervision ("BCBS") and the International Organization of Securities Commissions ("IOSCO") with respect to the Consultative Document "Margin requirements for non-centrally-cleared derivatives" of July 2012. Specifically, ISDA expressed its concern that the severe application of the proposals, as presented in the consultation, has the potential to undermine systemic resiliency by significantly affecting liquidity in financial markets and the general economy. Lofchie Comment: ISDA's response to IOSCO, and IOSCO's reaction, also has significance

SIFMA has published comments to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision (BCBS) and IOSCO on the Consultative Document on margin requirements for non-centrally-cleared derivatives. This letter includes a proposed universal two-way initial margin requirement aimed at ensuring that interconnected intermediaries have sufficient resources to withstand a major counterparty default without transmitting the resulting losses to third parties. SIFMA further recommends suggestions regarding: Segregation of initial margin; Cross-margining and

The MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee and the Board of IOSCO in response to the Basel-IOSCO Consultative Document on Margin Requirements for Non-Centrally-Cleared Derivatives. In the letter, the MFA urged the WGMR to take into consideration the importance of certain non-cleared derivatives as customized risk management tools, and set forth positions and recommendations on the following issues: Initial margin; Portfolio margining; Margin thresholds; IM schedule; and Ongoing review of requirements. View comment letter here

SIFMA's Asset Management Group (AMG) submitted the attached comment letter to the CFTC, OCC, Federal Reserve Board, FDIC, FCA, FHFA and BCBS/IOSCO regarding margin requirements for uncleared swaps for SDs and MSPs. The letter covers a wide variety of topics from the scope of applicability of the margin rules, margin calculation procedures, eligible collateral, handling of collateral, trading with affiliates to cross-border issues. Lofchie Comment: One of the many problems that Dodd-Frank creates is that it is far too prescriptive in what it requires; that is particularly a problem because some

The banking regulators (the "Agencies") have reopened the comment period for the "Proposed Margin Rule" published in the Federal Register on May 11, 2011 ( 76 FR 27564 ). The rule is intended to establish minimum margin and capital requirements for uncleared swaps and security-based swaps entered into by SDs, MSPs, security-based swap dealers, and major security-based swap participants, in each case subject to the requirements of the Prudential (banking) regulators rather than the CFTC. The release indicates that the comment period has been extended as a result of the consultative document on