CFTC Guidance Regarding Recent Amendment to Regulation 39.13(g)(8)(ii)

Since becoming effective on January 27, 2021, an amendment to US Commodity Futures Trading Commission (“CFTC”) Regulation 39.13(g)(8)(ii), passed in January 2020 (the “2020 Amendment”)1, has raised concerns among some market participants about futures commission merchants (“FCMs”) coming under commercial pressure to collect less initial margin, leading to heightened overall risk. At the core of… Continue reading CFTC Guidance Regarding Recent Amendment to Regulation 39.13(g)(8)(ii)

ISDA Publishes 2018 Credit Support Documentation for Mandatory Initial Margin

As you may have seen, ISDA recently published the ISDA 2018 Credit Support Annex for Initial Margin (IM) (Security Interest – New York Law) and the ISDA 2018 Credit Support Deed for Initial Margin (IM) (Security Interest – English Law). These new 2018 CSA/CSD forms are intended for use by buy and sell-side firms that… Continue reading ISDA Publishes 2018 Credit Support Documentation for Mandatory Initial Margin

ISDA Publishes Variation Margin Protocol to Address Certain Margin Rules for Uncleared Swaps

On August 16, 2016 ISDA published the ISDA 2016 Variation Margin Protocol, which is designed to amend ISDA Credit Support Annexes (“CSAs”) to take account of certain new margin requirements for uncleared swaps.

ISDA Publishes August 2012 DF Protocol to Address Dealer Business Conduct Standards and Other Rules – Teigland-Hunt LLP Client Alert

Earlier this week ISDA published the ISDA August 2012 DF Protocol (the “DF Protocol”), which is now open for adherence. What It Does: By adhering to the DF Protocol, parties will amend and supplement swap trading documentation to facilitate compliance with a number of final Commodity Futures Trading Commission (“CFTC”) rules, including the CFTC’s business… Continue reading ISDA Publishes August 2012 DF Protocol to Address Dealer Business Conduct Standards and Other Rules – Teigland-Hunt LLP Client Alert