Two of the US prudential regulators[1], the FDIC and the OCC, have voted to jointly adopt final rules regarding the exchange of initial and variation margin for uncleared swaps. The rules will apply to entities that are i) under the supervision of a prudential regulator ii) have registered with the CFTC or SEC as a […]

The five leading US regulatory agencies, collectively referred to as the “prudential regulators”[1], met yesterday to finalise the US iteration of the Basel III Liquidity Coverage Ratio, to adopt a supplementary leverage ratio rule and to propose new margin requirements for uncleared swaps. Liquidity Coverage Ratio– a deleveraging rule to protect financial institutions from temporary […]

On 6 August 2014, 11 US banks received a reminder by their regulators that the rights on early termination in their ISDA Master Agreements will require material changes in order to provide credibility for their living wills. This comment likely applies to every institution which is required to produce a living will under the Dodd-Frank […]

Regulators from the US and EU met on 8 July to host a meeting of the Financial Markets Regulatory Dialogue. Each side brought an alphabet of agencies, subjects covered included key G20 reforms: Basel II capital\leverage\liquidity rules, respective implementation of derivatives reforms, and resolution planning[1]. Derivatives– a mutual pledge to provide greater certainty regarding trading, […]

Dodd-Frank Section 619 “Prohibitions on proprietary trading and certain relationships with hedge funds and private equity funds”, more snappily known as the “Volcker Rule”, has recently undergone some incremental developments. The FRB, OCC, FDIC, SEC and CFTC jointly issued a FAQs document addressing the following matters: The reporting dates and date rules for trading metrics. […]

The FDIC filed a lawsuit in the federal district of New York, on Friday 14th March, accusing 16 of the world’s largest banks[1] of manipulation of the discredited benchmark rate-series, committing fraud and violating U.S. antitrust laws. The suit is made on behalf of a group of 38 U.S. banks, all casualties of the 2008 […]

The five main U.S. regulatory agencies have issued final rules[1], implementing Section 619 of Dodd-Frank- the Volcker Rule. Implementation is delayed by a year, giving banks until 21st July 2015 to be fully compliant. However, the order specifies that proprietary trading operations should be closed “promptly” and that the largest banks must begin reporting various […]

The House of Congress voted yesterday to repeal the controversial “push-out rule”.  Also referred to as the “Lincoln Amendment” (Blanche not Abe), Section 716is a prohibition on Federal assistance to swaps entities. The Section is broadly-drafted, “Federal assistance” includes FDIC guarantees and the use of the Fed’s discount window, while “swaps entity” comprises both dealers […]

On 15 April 2013, the Federal Reserve Board (FRB) and Federal Deposit Insurance Corporation (FDIC) issued a press release providing revised guidance for large US banks and foreign banks with USD 250 billion or more in total nonbank assets in completing their 2013 resolution plan submissions and granting an extension to the filing date for […]