Skip to main content
U.S. flag

An official website of the United States government

Dot gov

The .gov means it’s official.
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you're on a federal government site.


The site is secure.
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.

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

Latham & Watkins LLP submits the attached letter in response to the request for public comment set forth in the proposed amendments to the Margin and Capital Requirements for Covered Swap Entities.


J. Ashley Weeks 


885 Third Avenue

New York, NY 10022-4834

Direct Dial: +1.212.906.4630

Fax: +1.212.751.4864



This email may contain material that is confidential, privileged and/or attorney work product for the sole use of the intended recipient.  Any review, disclosure, reliance or distribution by others or forwarding without express permission is strictly prohibited.  If you are not the intended recipient, please contact the sender and delete all copies including any attachments.Latham & Watkins LLP or any of its affiliates may monitor electronic communications sent or received by our networks in order to protect our business and verify compliance with our policies and relevant legal requirements. Any personal information contained or referred to within this electronic communication will be processed in accordance with the firm's privacy notices and Global Privacy Standards available at