CFTC Issues Advisory Clarifying Documentation and Other Requirements for Covered Swaps with Counterparties Below $50 Million Phase Five Initial Margin Threshold | Practical Law
The CFTC issued an advisory clarifying that documentation governing the posting, collection, and custody of initial margin (IM) for uncleared derivatives under CFTC rules is not required to be completed until a party is required to post IM in an amount that exceeds the $50 million threshold for posting under the rules. The advisory was issued to clarify application of a recent BCBS/IOSCO statement on this matter to the CFTC margin rules.