FIA’s commodities members generally support the two CFTC proposals regarding the “Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants.” The Proposals seek to amend the current margin requirements for uncleared swaps for Swap Dealers and Major Swap Participants for which there is no prudential regulator. FIA appreciates the Commission’s efforts to update its rules where necessary to correct errors and relieve burdens on market participants. In particular, FIA’s commodities members support the introduction of the alternative initial margin (IM) calculation methodology, as discussed in the comment letter and as discussed in the Commission’s GMAC report entitled “Recommendations to Improve Scoping and Implementation of Initial Margin Requirements for Non-Cleared Swaps” while asking the Commission to remove the limitation on hedging transactions.
Further, FIA’s letter briefly addresses other important issues identified by FIA’s commodities members related to the CFTC margin rules for further consideration and action by the Commission.
Download the letter here.
- Dodd Frank
- Public Policy Submissions