Swap Dealers and Major Swap Participants Regulation - Comment Letter - Fannie Mae - July 8, 2011
|Original Proposal||Re-proposal Approved||Final Rule Approved|
|May 12, 2011||September 17, 2014||December 16, 2015|
Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants
July 8, 2011
Summary of key points from the comment letter:
- "Segregating variation margin (VM) will increase costs and decrease transparency; counterparty risk mitigation can be achieved in other manners without the need for VM segregation."
- "Requiring custodians to be independent and located in a jurisdiction that applies the same insolvency regime as the posting party may not be practical in all instances."
- "Margin rules should be consistent across regulatory bodies to the greatest extent practicable."