Staff members of the CFTC Office of the Chief Economist concluded that Phase 5 of the initial margin regime implementation will capture a substantial number of entities with a relatively low average aggregate notional amount ("AANA") of swaps, and with a high proportion of physically settled FX swaps. The economists prepared the newly released paper as a guide for regulators as they respond to requests for relief by market participants who had argued that Phase 5 (which goes into effect on September 1, 2020) would bring a substantial number of relatively small market participants into scope
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Two large buy-side trade groups asked regulators to provide transitional relief from the March 1 compliance date for variation margin requirements.
The NFA Executive Committee increased the minimum security deposits required to be collected and maintained by Forex Dealer Members.
The Executive Committee of the NFA increased the required minimum security deposit for Forex Dealer Member transactions involving the British pound to 5% of the notional value of transactions.
SIFMA Asset Management Group ("SIFMA AMG") submitted comments to the European Supervisory Authorities ("ESAs") on the second Consultation Paper concerning risk-mitigation techniques for OTC-derivative contracts that are not centrally cleared. The SIFMA AMG explained that it did not respond to each of the specific questions posed by the ESAs – rather, it focused on the wider concerns relating to the application of the margin requirements. In particular, the SIFMA AMG stressed that: equivalence decisions should be made in good time prior to the implementation of EU margin requirements so as to