Derivatives Clearing Organizations Regulation - Comment Letter - ISDA/SIFMA - 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:

  • The proposed conditions relating to the collection of variation margin and the extraterritorial clearing of swaps related to interaffiliate swaps should be eliminated.
  • In the event that the Commission decides to retain the variation margin condition, it should make certain changes and clarifications to the proposed rule text, including the elimination of the “common guarantor” requirement from its proposed exception to the variation margin condition.
  • In the event that the Commission decides to retain the extraterritorial clearing condition, it should provide for an appropriate transition period to allow foreign jurisdictions time to implement their G-20 clearing mandates and should make certain other changes and clarifications.
  • The trade execution requirement should not apply to interaffiliate swaps, regardless of whether the conditions for the interaffiliate clearing exemption are met.
  • The Commission should adopt a more flexible formulation of the proposed documentation requirement.



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