CFTC issues two no action letters on non-cleared margin
Published: 17 February 2017
The CFTC last week issued two time-limited no-action letters.
The first no-action letter grants a grace period from compliance with the CFTC variation margin requirements until 1 September 2017 for circumstances either where: (i) the necessary credit support documentation has not been completed with the relevant counterparty; or (ii) the relevant Swap Dealer, despite bona fide best efforts, needs more time to implement operational processes to comply with the rules.
The second no-action letter grants relief to Swap Dealers from the Minimum Transfer Amount requirement of US$500,000 when facing separately managed accounts a single entity across different asset managers. This relief effectively permits the parties to treat each separately managed account as an individual counterparty with a new minimum transfer amount of US$50,000.
If members have questions or comments, please contact Adam Jacobs-Dean, Oliver Robinson or Adele Rentsch.
