Letter to the CFTC in Support of Proposals on Margin Requirements for Uncleared Swaps

On October 22, 2020, MFA submitted a letter to the CFTC in support of its proposals on margin requirements for uncleared swaps for swap dealers and major swap participants. The proposals will align the calculation method for material swap exposure with the BCBS-IOSCO framework and codify the no-action relief previously granted in relation to minimum transfer amounts for initial and variation margin. MFA supported the proposals but did encourage the Commission to consider several additional changes to its margin rules that will improve coordination with other regulators and prevent confusion and market disruption