Alert May 17, 2011

CFTC Extends Comment Period for Proposed Margin Regulations

The CFTC issued a notice extending until July 11, 2011 the comment period on its earlier proposal regarding initial and variation margin requirements for swap dealers (“SDs”) and major swap participants (“MSPs”) (as discussed in the May 3, 2011 Alert) in order to allow its comment period to run concurrently with that of a related proposal.  Under the related proposal, the CFTC would amend existing capital and financial reporting regulations for futures commissions merchants (“FCMs”) that also register as SDs or MSPs, and provide for supplemental FCM financial reporting relating to the segregation of swap customers’ funds (as discussed in the May 3, 2011 Alert).