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Commentary by Nihal Patel

The SEC adopted changes to the exemptions for certain clearing agencies and broker-dealer/futures commission merchants concerning the portfolio margining of swaps and security-based swaps that are cleared credit default swaps.

Commentary by Nihal Patel

In response to a request from ISDA and SIFMA, the SEC Division of Trading and Markets will not recommend enforcement action if a security-based swap dealer does not collect initial margin from certain counterparties in connection with an uncleared security-based swap entered into prior to September 1, 2022.