Tag Archives: margin on swaps

Comparing Collateral Segregation Regimes for Uncleared Swap Margin

The proposed margin rules from the CFTC and the prudential regulators, when considered alongside the existing CFTC collateral segregation rules, present the potential for three different collateral segregation regimes applying to initial margin posted to a swap dealer. To compare the differences, we have created a chart of the three collateral segregation regimes.… Continue Reading

The Debt Ceiling Debate: It’s not Just for CDS Anymore

By Andrew Cross and Tom Watterson Last week ISDA announced that, in the event of a default by the U.S. on its debt following the failure to raise the debt ceiling, the sellers of CDS on U.S. debt would pay-out, at most, only $3.6 billion. The potential default, however, is also impacting the interest rate swap … Continue Reading

DOL Advisory Opinion 2013-01A: Cleared Swaps Under ERISA – Margin Not a Plan Asset / CCPs & FCMs Are Not Fiduciaries / No Prohibited Transactions (By Andrew P. Cross and Allison W. Sizemore)

By Andrew P. Cross and Allison W. Sizemore, Reed Smith LLP This posting summarizes Advisory Opinion 2013-01A, which was issued by the U.S. Department of Labor in February 2013 in order to address key interpretive issues relating to the ability of pension plans to trade centrally cleared swaps.  This posting will be of interest to pension … Continue Reading

Mutual Fund Corner: July 16th and 17f-6 No Action Letters

In an earlier posting – available here, we reported that the SEC issued several No Action Letters that have the combined effect of permitting registered investment companies to posting initial margin on cleared swaps directly with their clearing member. By their terms, the no-action relief provided by these letters expires on July 16, 2011. Q1:Why? … Continue Reading

WSJ Reports “Sudden Silver Plunge Erases Rally” – The Stash Crash?

Page C2 of today’s WSJ contains an article entitled, “Sudden Silver Plunge Erases Rally.”  In summary, the primary exchange on which silver futures contracts trade and (at least one large) futures commission merchant raised the margin requirements on these contracts. According to the article, the increase for speculative traders equaled about 24% of the margin … Continue Reading

MARGIN REQUIREMENTS: On the Agenda for the 13th Public Meeting

The CFTC has announced that it will hold its (rescheduled) 13th Public Meeting on Dodd-Frank Reforms on Tuesday, April 12th at 9:30 a.m. EST. On the agenda…"Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants"… Press Release and "How to Participate" is available here. Good day. Good reading. TSR.… Continue Reading