Now that we know the effective date of the EU rules for the margining of uncleared swaps, we have created an up-dated and final version of the comparison of the EU and US margin rules that we originally created in conjunction with US law firm, Kramer Levin.
For those who have received this previously, the latest changes are:
- Effective date of rules (including policies, procedures and netting and collateral legal reviews) – 4 January 2017
- Effective date for IM and VM for phase one swap dealers – 4 February 2017
- Effective date for VM for all FCs/NFC+s and equivalents – 1 March 2017
- Latest industry interpretation of the settlement period for margin calls under the European rules, being now next day for cash as long as the transfer is initiated on the day of the call
If you have any questions about the rules or how to comply with them, please let us know. We also offer implementation solutions which we would be happy to discuss with you.