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Commentary by Steven Lofchie

SIFMA provided notice to banking regulators (the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency and the FDIC) of a forthcoming change in the treatment of variation margin payments for over-the-counter derivatives by central clearing counterparties ("CCPs"). Historically, variation margin payments have been treated as collateral for outstanding exposure, a treatment that a SIFMA comment letter refers to as the "collateralized to market" ("CTM") model. Going forward, the CCPs will adopt a model by which variation margin payments are treated as settlement