Clifford Chance

CFTC no-action letters address variation margin deadline and minimum transfer amounts

15 February 2017

On February 13, 2017, the U.S. Commodity Futures Trading Commission's Division of Swap Dealer and Intermediary Oversight issued a no-action letter granting limited relief relating to the CFTC's variation margin requirements until September 1, 2017. The DSIO also issued a no-action letter that grants exemptive relief related to the application of the minimum transfer amount to separately managed accounts. The relief discussed in this briefing applies only to dealers subject to the CFTC's margin rules and does not apply to any swap dealer that is subject to the margin rules issued by the U.S. prudential regulators.

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