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Return to Comments
Margin and Capital Requirements for Covered Swap Entities Proposed Rule (LIBOR Amendments)
Type: Regulation
Federal Register Document Type: Proposed
Would amend the regulation governing Margin and Capital Requirements for Covered Swap Entities to clairify that certain non-cleared swaps would retain their legacy status if they are amended solely to substitute another reference rate for LIBOR as it is phased out and to address other issues.

Text of Comment Letter

Good afternoon,  

Attached please find the Structured Finance Association (SFA) response to the proposal put forth by the Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency on the regulation that would permit covered swap entities to amend the reference rates in a legacy swap contract and to adopt necessary follow-on amendments without converting the legacy swap into a swap subject to Swap Margin Rule. Please reach out to me with any questions.

Thank you. 

Best Regards,

Hunter Hamrick | Policy Development Analyst

Office: (202) 524 6307 | StructuredFinance.orgcid:image003.png@01D5AEAD.3709C4E0