Highlights of the Final Prudential Regulator Margin Rules for Non-Cleared Swaps

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The US prudential regulators (the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing Finance Agency) have each adopted (1) a final margin rule, and (2) an interim final margin rule (collectively, the "Rules") that set mandatory margin requirements for swap dealers, security-based swap dealers, major swap participants and major security-based swap participants (each, a "Swap Entity" or SE) that are regulated by those agencies (each, a "Covered Swap Entity" or CSE). The Rules apply to any swap or security-based swap of a CSE that is not cleared with a derivatives clearing organization or clearing agency.

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