Tag Archives: swaps

ABA Urges CFTC to Adopt Risk-Based Measure for Swap Regulations

ABA today welcomed the Commodity Futures Trading Commission’s proposal to set the swap dealer de minimis threshold at $8 billion on a permanent basis while noting that it could be set even higher or, preferably, replaced with a risk-based threshold instead of a fixed aggregate gross notional amount of swaps.

Read More »

ABA Weighs in on Harmonization of Swap Margin, QFC Rules

ABA today commented on a joint proposed rulemaking issued by the OCC, Federal Reserve and FDIC, Farm Credit Administration and the Federal Housing Finance Administration that would align the agencies’ margin rules with restrictions on qualified financial contracts that took effect last year.

Read More »

Agencies Propose Harmonizing Swap Margin, QFC Rules

To facilitate compliance with their rules regarding qualified financial contracts of systemically important banks, the federal banking agencies today proposed a rule clarifying that legacy swaps -- those entered into before the margin rules’ compliance dates -- do not become subject to margin requirements provided they are amended solely to comply with QFC rules.

Read More »

ABA Calls for Clarity, Flexibility on Eligible Contract Participant Definition

As the Commodity Futures Trading Commission continues its ongoing initiative to simplify and modernize its rules, ABA last week wrote to the CFTC to highlight how a relatively inflexible definition of “eligible contract participant” under CFTC regulations has constrained banks from helping borrows mitigate risk by participating in swaps transactions.

Read More »