MFA Letter on Delaying Phase 5 and 6 of the Uncleared Margin Rules

On August 5th, MFA and several other associations submitted a letter to the CFTC in support of its decision to provide timely and valuable regulatory relief to market participants through its Interim Final Rule and Notice of Proposed Rulemaking with respect to the CFTC’s Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants. These rulemakings defer the compliance date for Phase 5 and 6 with respect to the application of initial margin requirements for covered swap entities and covered counterparties with an average aggregate notional amount exceeding $50 billion (Phase 5) and material swaps exposure (i.e., $8 billion) (Phase 6). The Associations supported the deferrals of the Phase 5 and 6 compliance dates as it would help facilitate orderly preparation for the exchange of regulatory initial margin between covered swap entities and covered counterparties.