Does CFTC’s Initial Margin Requirement for Inter-affiliate Uncleared Derivatives Transactions Disadvantage U.S. Banking Organizations?

Sangil Min

In September 2019, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, and Federal Housing Finance Agency proposed rules amending current swap margin requirements for covered swap entities (“CSE”), and have since gathered comments from industry stakeholders.


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