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.

https

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
Description:
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

FCA RIN 3052–AD38 – Margin and Capital Requirements for Covered Swap Entities

To Whom it May Concern,

Please find attached a supplemental comment letter from the Alternative Reference Rates Committee, responding to the Farm Credit Administration’s Notice of Proposed Rulemaking Regarding Margin and Capital Requirements for Covered Swap Entities.

Sincerely,

Simon Winn

Co-Chair, Alternative Reference Rates Committee, Regulatory Issues Working Group

From: Bindra, Priya (LEGAL)
Sent: Monday, December 9, 2019 2:39 PM
To: 'reg-comm@fca.gov' <reg-comm@fca.gov>
Subject: FCA RIN 3052–AD38 -- Margin and Capital Requirements for Covered Swap Entities

FCA RIN 3052–AD38 – Margin and Capital Requirements for Covered Swap Entities

To Whom it May Concern,

Please find attached the Alternative Reference Rates Committee’s response to the Farm Credit Administration’s Notice of Proposed Rulemaking Regarding Margin and Capital Requirements for Covered Swap Entities.

Sincerely,

Priya Bindra

Co-Chair, Alternative Reference Rates Committee, Regulatory Issues Working Group

Priya Bindra, Executive Director   
Morgan Stanley | Legal and Compliance   
Priya.Bindra@morganstanley.com   
   

NOTICE: Morgan Stanley is not acting as a municipal advisor and the opinions or views contained herein are not intended to be, and do not constitute, advice within the meaning of Section 975 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. If you have received this communication in error, please destroy all electronic and paper copies and notify the sender immediately. Mistransmission is not intended to waive confidentiality or privilege. Morgan Stanley reserves the right, to the extent required and/or permitted under applicable law, to monitor electronic communications, including telephone calls with Morgan Stanley personnel. This message is subject to the Morgan Stanley General Disclaimers available at the following link: http://www.morganstanley.com/disclaimers.  If you cannot access the links, please notify us by reply message and we will send the contents to you. By communicating with Morgan Stanley you acknowledge that you have read, understand and consent, (where applicable), to the foregoing and the Morgan Stanley General Disclaimers.

You may have certain rights regarding the information that Morgan Stanley collects about you. Please see our Privacy Pledge
https://www.morganstanley.com/privacy-pledge for more information about your rights.

Classification: Public
This message and any attachments (the "message") is intended solely for the addressees and is confidential. If you receive this message in error, please delete it and immediately notify the sender. Any use not in accord with its purpose, any dissemination or disclosure, either whole or partial, is prohibited except formal approval. The internet can not guarantee the integrity of this message. BNP PARIBAS (and its subsidiaries) shall (will) not therefore be liable for the message if modified. Please note that certain functions and services for BNP Paribas may be performed by BNP Paribas RCC, Inc.
Unless otherwise provided above, this message was sent by BNP Paribas, or one of its affiliates in Canada, having an office at 1981 McGill College Avenue, Montreal, QC, H3A 2W8, Canada. To the extent this message is being sent from or to Canada, you may unsubscribe from receiving commercial electronic messages by using this link: www.bnpparibas.ca/en/unsubscribe/. See www.bnpparibas.ca for more information on BNP Paribas, in Canada.

Attachments: