CFTC delays implementation of OTC collateral rules

15 February 2017 The US Commodity Futures Trading Commission issued on Monday no-action letter 17-11, granting swap dealers time-limited relief from compliance with the obligation to post and collect variation margin from their OTC swaps counterparties. Note however that no-action letter 17-11’s relief expires on 1 September 2017 and is […]

Fractured regulatory landscape as OTC collateral deadline looms

26 August 2016 Only days away from the 1 September regulatory deadline for the new collateral regime, it seems clear that, absent a last-minute no-action letter from the only three regulators poised to meet the original deadline, (namely, the US, Canada and Japan), the $493 trillion OTC derivatives market, the […]

The EU launches CDS clearing obligation

28 April 2016 The EU launches CDS clearing obligation The European Commission published on 19 April 2016 the regulatory technical supplement for credit default swaps (“CDS”), setting out the types of transaction subject to the clearing obligation, as well as the entry into force of the clearing obligation (and frontloading […]

EU grants US CCP equivalency

17 March 2016 EU grants US CCP equivalency The European Commission has accepted US central counterparty (CCP) regulations as equivalent to its own, allowing US CCPs to apply to the European Securities and Markets Authority for derivatives clearing status. This follows the announcement of a common approach to CCP equivalence […]

Dodd-Frank’s end user vs. EMIR’s NFC-: interchangeable terms?

05 January 2015 Regardless of the nationality or domicile of their clients, European banks must still comply with European regulation. Such banks are finding it difficult for some of their US clients to agree to make certain representations under EMIR. If those banks also happen to be registered as swap […]