Swap Dealers and Major Swap Participants Regulation - Comment Letter - MetLife - July 11, 2011

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Dodd-Frank Timeline, Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants, CFTC
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 11, 2011

Recommended modifications from the comment letter:

  • Expanding the range of eligible collateral to include High-quality Corporate Bonds and Agency RMBS;
  • Reducing initial margin requirements to be more consistent with comparable cleared trades and consistent with the actual risk of the particular transaction;
  • Preserving mutual two-way netting and collateral arrangements consistent with current market practice;
  • Providing a measure of flexibility to financial end users and CSEs in the calculation of initial margin, the choice of margin model; and
  • Phasing-in new margin requirements in coordination with clearinghouse capabilities and in coordination with U.S. and foreign derivatives regulations.


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