Recently, the Federal Reserve, several other banking regulators and the CFTC published final rules governing uncleared swap margin requirements. Regulations governing margin delivery requirements for uncleared swaps will become effective starting September 2016. Directly regulating swap dealers like banks and brokerage firms, the rules also significantly affect over-the-counter derivatives contracts of private funds and other buy-side counterparties who trade with regulated entities. Financial end-users should begin preparing well in advance of upcoming effective dates.
In this client alert, Richards Kibbe & Orbe attorneys Julia Lu and John A. Clark discuss the pending impacts of the new rules and answer important high-level questions to help acquaint fund managers and their counsels with the uncleared swap margin requirements.