Last week, Chatham offered its comments together with the Coalition for Derivatives End-Users to proposed regulatory rules concerning margin requirements for uncleared swaps. While challenging the regulators’ assertion of authority to impose margin requirements on end-users, the Coalition also identified specific ways in which the proposed margin framework could be improved. Read the comments to prudential regulators HERE
(these cover trades executed with bank swap dealers) and to the CFTC HERE (these cover trades executed with non-bank swap dealers).

Notably, these comments were endorsed by a broad cross-section of American businesses. The Association for Financial Professionals, Business Roundtable, Commodity Markets Council, Financial Executives International, National Association of Corporate Treasurers, National Association of Manufacturers, National Association of Real Estate Investment Trusts, The Real Estate Roundtable and the U.S. Chamber of Commerce each signed the letters.

If you have questions or concerns about proposed margin rules or any other regulatory developments, please call your friendly Chatham consultant or a member of our regulatory advisory team (Pam Brown: 484-731-0414; Luke Zubrod: 610-925-3136).