Swap Dealers and Major Swap Participants Regulation - Comment Letter - Fannie Mae - July 8, 2011

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Dodd-Frank Timeline, Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants, CFTC
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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."


References[edit]

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