This report assesses FRB action on a rewrite of U.S. margin rules for non-cleared swaps, with subsequent alerts assessing the FDIC’s action today on the same requirement. The new margin rule is a significant departure from the very controversial 2011 inter-agency proposal. Most significantly, the agencies have reversed their longstanding view that end-users would need to hold margins; now, the proposal requires only that end-users do so if counterparties determine this to be necessary for risk-management purposes. The proposal is, however, still strict and in several respects far more stringent than the relevant international accord and pending proposals in the EU and Japan.
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