Covered Swap Entities Regulation - Comment Letter - BNY Mellon/Northern Trust/State Street - July 11, 2011
|Re-proposed Rule Issue||Final Rule Issue||Effective Date|
|September 24, 2014||October 22, 2015||April 1, 2016|
Margin and Capital Requirements for Covered Swap Entities
July 11, 2011
From the comment letter:
"While the Custodian Banks believe the use of independent custody for swaps margin provides high levels of protection for each counterparty to a swap, for the reasons set forth herein, we are concerned that including the insolvency regime-related requirement in a final rule would not mitigate risks faced by Swap Entities that enter into Uncleared Swaps and would have undesirable consequences. Accordingly, we respectfully request that the insolvency regime requirement be excluded from the final rulemaking."