Posts Tagged ‘CFTC’

Another Common Sense Win For End-Users Under Dodd-Frank

Better late than never. Last week the CFTC provided a no-action letter recommending that the Commission does not enforce the requirement for inter-affiliate swap reporting under Part 45 governing Swap Data Repository (SDR) rules.  Under these rules, a non-financial corporate that centralizes its hedging activity by consolidating its group needs into a larger dealer-facing swap…

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Two years later, the Dodd-Frank train has left the station.

With the passing of the Swap Definition rule on Tuesday, July 10th the clock really starts ticking as some key rules are going into effect this fall.  Any rational person would assume that before you write rules governing Swaps, you start with the simple task of defining the Swap.  Unfortunately life in the derivative world…

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Reval Comments to CFTC on Margin Rules

Comments to the CFTC on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants closed on Monday. Reval’s comment letter outlines potential impacts to end-users.

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End-User Clearing Exemption Marginalized By Swap Dealer Margin Rules

Reval CEO Jiro Okochi urges End-Users to pick up the pen or make the pilgrimage to DC before the proposed margin requirements issued by the Prudential Regulators and CFTC become final, as they will have a direct cost impact on End-Users, whether it’s through legal fees or the cost to fund the posting of collateral.

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More Clarity on the End-User Clearing Exemption: FAS 133 (ASC 815) Ratified, Small Banks in Limbo

The big fear of just relying on FAS 133 was for all of the end-users who would not get the clearing exemption because either they could not be bothered to comply with FAS 133 or because their hedging programs did not work well under FAS 133, like many commodity hedges. The CFTC’s approach does allow the flexibility to leverage FAS 133 documentation where a company can and use other approaches where a company cannot.

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