Derivatives Clearing Organizations Regulation - Comment Letter - Financial Services Roundtable - September 20, 2012

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Timeline-Inter-Affiliate Swaps
Proposal Date Final Rule Issue Effective Date
August 21, 2012 April 11, 2013 June 18, 2013

Clearing Exemption for Swaps between Certain Affiliated Entities
September 20, 2012

Recommendations from the comment letter:

  • Clarify no requirement to exchange initial margin.
  • Limit requirement to exchange variation margin to circumstances in which entities are subject to affiliate transaction restrictions under other applicable law.
  • Requirements for variation margin for inter-affiliate swaps should be clarified.
  • Financial entities with 100% common ownership should not be required to post margin to each other, even if they do not have a common guarantor.
  • The inter-affiliate exemption should apply to swaps between two non-U.S. affiliates, even if such non-U.S. affiliates are not located in countries with clearing regimes comparable to the U.S. regime.
  • Eliminate requirements for integrated risk management.



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