New York, 14 April 2011

On April 12, 2011, the Commodity Futures Trading Commission ("CFTC") voted 4-1 to issue proposed rules establishing minimum initial and variation margin requirements for non-cleared swaps entered into by CFTC-regulated swap dealers and major swap participants.

Later the same day, the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration and the Federal Housing Finance Agency (collectively, "Prudential Regulators") jointly issued their own rules establishing margin requirements for swap dealers and major swap participants that are subject to their respective prudential regulation.

If adopted, the proposed rules will potentially impact all users of over-the-counter derivatives products, including commercial end-users that use swaps primarily to manage the risks associated with their businesses.

Source: Cadwalader, Wickersham & Taft LLP.

www.Cadwalader.com

Attachments:

CFTCPrudentialRegProposeMargin.pdf

595 Kb